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Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 2 of 12 BACKGROUND At the heart of this case lies Ms. Giuffre’s allegations that that she was sexually abused by Jeffrey Epstein and the Defendant. Ms. Giuffre has also alleged that Epstein and the Defendant were aided by others who played keys roles in the sex trafficking organization, including Sarah Kellen and Nadia Marcinkova. Defendant has called Ms. Giuffre a “liar” and Ms. Giuffre is now in the process of assembling testimony and evidence to prove the truth of her allegations. Apart from the Defendant in this case, Jeffrey Epstein is the most important person for Ms. Giuffre to depose. It was Epstein who gave the directions to Maxwell to recruit Ms. Giuffre and bring her to Epstein’s mansions to be sexually abused. At several points during her recent deposition, Ms. Maxwell refused to answer Ms. Giuffre’s questions about Epstein, but instead told her she should go ask Epstein about the subject. See, e.g., Tr. of Depo. of Defendant (Apr. 22, 2016) at 100 (“Q: ... [W]as it Jeffrey’s preference to start a massage with sex? .. . A: I think you should ask that question of Jeffrey.”); id. at 146-47 (“Q: So would [Ms. Giuffre] be brought on trips that were for the purpose of work and decorating the house? A: Like I said, I never worked with her but you would have to ask Jeffrey what he brought her on the trip for.”); id. at 389-90 (“Q: Does [Epstein] . . . have any knowledge of any illegal activity that you’ ve conducted? ... A: If you want to ask Jeffrey questions about me, you would have to ask him.”). See McCawley Decl. at Exhibit 2. Because of Epstein’s importance to this case, Ms. Giuffre has diligently tried to personally serve Epstein with a subpoena for his deposition. Epstein, however, appears to have no interest in answering questions under oath about the scope of his sex trafficking organization and he has not authorized his lawyer to accept service of the subpoena. On March 7, 2016, Ms.