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Case 1:15-cv-07433-LAP Document 1320-21 Filed 01/03/24 Page 6 of 15 e Ina 2011 interview, Ms. Giuffre mentioned former President Bill Clinton’s close personal relationship with Defendant and Jeffrey Epstein. While Ms. Giuffre made no allegations of illegal actions by Bill Clinton, Ms. Maxwell in her deposition raised Ms. Giuffre’s comments about President Clinton as one of the “obvious lies” to which she was referring in her public statement that formed the basis of this suit. Apart from the Defendant and Mr. Epstein, former President Clinton is a key person who can provide information about his close relationship with Defendant and Mr. Epstein and disapprove Ms. Maxwell’s claims. Ms. Giuffre is still working diligently with opposing counsel, these witnesses, and their attorneys on scheduling, as well as identifying other witnesses who may have factual information about the case. But, at this time, she seeks this Court’s approval for an additional three depositions — depositions that will not consume the full seven hours presumptively allotted. All three prongs of the three-factor test to evaluate a motion for additional depositions strongly support granting the motion. Atkinson v. Goord, No. 01 CIV. 0761 LAKHBP, 2009 WL 890682, at *1 (S.D.N.Y. Apr. 2, 2009). First, as reviewed in detail on a witness-by-witness basis above, the discovery sought is not duplicative. The proposed deponents include the individual who assisted in making the defamatory statement, women Defendant Maxwell hired to recruit girls for Jeffrey Epstein, an individual with intimate knowledge of Defendant and Epstein’s sexual trafficking ring, other victims of Jeffrey Epstein (including a then underage victim), Mr. Epstein himself, and other witnesses who can corroborate important pieces of Ms. Giuffre’s statements or refute Ms. Maxwell’s statements and positions. These witnesses’ testimony will corroborate Ms. Giuffre’s account of Defendant being a recruiter of females for Epstein and corroborate the type of abuse she and others suffered. Sadly, Ms. Giuffre is far from the only one of Defendant’s victims, and there are other witnesses whose testimony is necessary in order to demonstrate the truth of Ms. Giuffre’s claims and the falsity of the statements made by Defendant.