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Case 1:15-cv-07433-LAP Document 1320-21 Filed 01/03/24 Page 5 of 15 fact of this dispute confirms, this case is going to be hotly contested and the weight of the evidence on each side is going to be vitally important. The Court is well aware of many other civil cases where the parties have taken far more than ten depositions by mutual agreement. Defendant’s refusal to agree to a few more depositions here is simply an effort to keep all the relevant facts from being developed. Since Ms. Giuffre filed her initial motion seeking seven additional deposition, she has worked diligently to try to streamline the necessary depositions and has discovered new information concerning witnesses and their knowledge of the claims in this case. Accordingly, Ms. Giuffre currently brings before this Court a significantly shorter list” of witnesses she needs to depose to prove her claim, with some alterations. To be clear, Ms. Giuffre has narrowed her request and is now only seeking an additional three depositions from the Court as follows: For descriptions concerning the depositions already taken (Defendant; Ms. Sjoberg; Mr. Alessi; Mr. Rodgers; and Mr. Rizzo), and those yet to be taken (Mr. Epstein; Mr. Gow; | Ms. Kellen; Ms. Marcinkova; Mr. Recarey; and Mr. Brunel), Ms. Giuffre references and incorporates her descriptions in the moving brief. The only remaining witness is William Jefferson Clinton. His deposition is necessary for the following reason: first one was it would take pressure off of Maxwell to have more girls around? A. Right. Q. What exactly did Maxwell say to you that led you to believe that was her implication? A. She said she doesn’t have the time or desire to please him as much as he needs, and that’s why there were other girls around.). That Ms. Sjoberg never saw Ms. Giuffre give a massage to Ms. Maxwell is immaterial. Ms. Sjoberg was with Defendant and Epstein when Ms. Giuffre was a minor child, and corroborates Ms. Giuffre’s accounts concerning her being trafficked to Prince Andrew. Jd. at 21-22. Ms. Giuffre refers the Court to Ms. Sjoberg’s deposition testimony in its entirety (DE 173-5). It is depositions like this - verifying Ms. Giuffre’s account of being recruited by Defendant for sex with Epstein — that Defendant is trying avoid. However, multiple other witnesses have testimony that supports Ms. Giuffre’s claims, in different and various ways, and Ms. Giuffre needs that testimony to prove her defamation claim against Defendant. > Ms. Giuffre is no longer seeking the deposition testimony of Emmy Taylor, a. Jo Jo Fontanella, and Michael Reiter.