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Case 1:15-cv-07433-LAP Document 1320-21 Filed 01/03/24 Page 4 of 15 Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this reply in support of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit and in light of recent developments, Ms. Giuffre has streamlined her request, and now seeks only a total of three additional depositions. Notably, while Defendant contests Ms. Giuffre’s motion, Defendant has herself unilaterally — and without seeking any Court approval — set twelve witnesses for deposition in this matter. In contrast to Defendant’s unilateral action, Ms. Giuffre has properly sought this Court’s permission. The Court should grant her motion and allow her to take the three additional depositions. I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL CLAIMS AND DEFENSES IN THIS CASE, AND NONE ARE DUPLICATIVE. Defendant argues that the depositions Ms. Giuffre seeks to take are somehow “duplicative” of each other. Even a quick reading of the Defendant’s pleading makes clear this is untrue. Defendant repeatedly gives her own narrow view of what existing witnesses have said. For example, Defendant argues that Ms. Sjoberg “did not corroborate that [Ms. Giuffre] is telling the truth.” Defendant’s Response at 5. Defendant’s characterization is untrue.’ But, as the mere ' Defendant wholly mischaracterized Ms. Sjoberg’s testimony as involving “professional massages.” Defendant’s Resp. at 5. In fact, Ms. Sjoberg testified that, when she was a twenty- one-year-old college student, Defendant (not Jeffrey Epstein) recruited and hired her under the pretext of being a personal assistant to provide sexual massages. As one example of this testimony, Sjoberg testified that Defendant became angry with her for not “finishing your job” when Defendant was the one who ended up having to bring Epstein to orgasm when Ms. Sjoberg did not. See McCawley Dec at Exhibit 1, Sjoberg Dep. Tr. at 142:25-143:14(Q. What did you understand Maxwell to mean when you said that you hadn’t finished the job, with respect to the camera? A. She implied that I had not brought him to orgasm. Q. So is it fair to say that Maxwell expected you to perform sexual acts when you were massaging Jeffrey? A. I can answer? Yes, I took that conversation to mean that it what was expected of me.) Ms. Sjoberg’s testimony also shows that Defendant was a predator of young women and girls, and that her business was to provide girls for Jeffrey Epstein to have sex with. /d. at 141:3-5; 150:16-151:2 (Q. Did Maxwell ever ask you to bring other girls over to — for Jeffrey? A. Yes. Q. I want to go back to this: You testified to two things just now with Sigrid that you said were implied to you. A. Okay. Q. The 1