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Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 4 of 10 Exhibit 1, April 22, 2016 Deposition of Defendant at p. 10-11, 410. As the Court knows, the Palm Beach Police Report demonstrates multiple incidents of “massages” being given by untrained minor children that involved sexual acts. See McCawley Decl. at Exhibit 3, Palm Beach Police Report. Defendant is also identified in that Palm Beach Police Report. See McCawley Decl. at Exhibit 3, Palm Beach Police Report at p. 75-76. And the details of Epstein’s sexual activities with Defendant (for example) are highly relevant to this case, because they will help corroborate Ms. Giuffre’s testimony that, while she was underage, she also engaged in sexual activity of an identical nature with Epstein. To allow Defendant to avoid answering these questions would preclude Ms. Giuffre from getting critical evidence in this case. Consider, for example, Defendant recruiting an eighteen year-old girl to be an “assistant,” bringing that girl to Epstein’s home, telling her she could make more money if she would give Epstein a massage, and then instructing her to give a massage that involved sexual acts. Under Defendant’s theory of discovery, Ms. Giuffre would be precluded from deposing her on that topic because the actions would culminate in “consensual adult sex.” Yet, that scenario would fully validate the pattern of events that occurred with Ms. Giuffre when she was under the age of eighteen. It would obviously show a “modus operandi” by Jeffrey Epstein and Defendant, which is clearly admissible under Fed. R. Evid. 404(b). Moreover, such inquiries are crucial to impeaching the Defendant at trial. During her deposition, Defendant attempted to characterize her work for Epstein as nothing more than a normal job handling hiring for the various mansions. See McCawley Decl. at Exhibit 1, April 22, 2016 Deposition Tr. of Defendant at p. 9-12. Ms. Giuffre should be able to contest that assertion by having Defendant fully answer questions about whether that alleged “job” involved