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Case 18-2868, Document 285, 08/09/2019, 2628246, Page2 of 4 3. On January 9, 2017, I also prepared and served on the Court and counsel, under seal, Defendant’s Statement of Material Undisputed Facts Pursuant to Local Civil Rule 56.1 (“Statement”). Those paragraphs mirror the numbered paragraphs contained within the Memorandum of Law, minus the citations to the evidentiary record. The Statement was filed with the Court in hard-copy and placed in the vault (see Doc.543). 4. Through a clerical oversight, a redacted version of the Statement was not appended to the filed ECF version of the Notice of Motion for Summary Judgment (Doc. 537). However, as noted in the previous two paragraphs, Ms. Maxwell enumerated all undisputed facts in accordance with Local Civil Rule 56.1(a) in: e Ms. Maxwell’s Memorandum of Law in Support of Motion for Summary Judgment (Doc.541); and e the Local Rule 56.1 Statement served on the the Court and counsel and filed in hard copy with the Court. 5. Attached as Exhibit NN (filed under seal) is a true and correct copy of Defendant, Ghislaine Maxwell’s Initial Disclosure Pursuant to Fed. R. Civ. P. 26, served February 24, 2016. 6. Attached as Exhibit OO (filed under seal) is a true and correct copy of an email correspondence from Plaintiff to Sharon Churcher, dated May 12, 2011, Bates stamped GIUFFRE004096-7; 004028-30. 7. Attached as Exhibit PP (filed under seal) are true and correct copies of excerpts from the November 14, 2016 deposition of Virginia Giuffre, designated Confidential under the Protective Order.