Giuffre_Maxwell_Batch1_p00528.png

Case 1:15-cv-07433-LAP Document 1320-21 Filed 01/03/24 Page 8 of 15 as young as 14 years old playing a “kissing game” with and for Jeffrey Epstein.* Finally, the Defendant appears to be concealing critical evidence of the sexual abuse that other witnesses ee. Yet Defendant has failed to produce a single photo in this case. See McCawley Decl. at Exhibit 3, Alessi Deposition at 36-41. Document discovery and interrogatories are not helpful in obtaining this type of evidence: depositions are needed. Third, the burden and expense of this proposed discovery is limited to three additional depositions. Defendant in this case is a multi-millionaire with able counsel. Three depositions will not cause her undue burden, expense, or inconvenience. These depositions are important to resolving issues in this case. Given that very few witnesses reside within 100 miles of the courthouse and therefore cannot be compelled to trial, this request for only three additional depositions is a reasonable request. While Defendant opposes Ms. Giuffre’s request for Court approval of more than ten depositions, she has unilaterally noticed more than ten depositions without bothering to seek approval. As of the date of this filing, Defendant’s counsel has issued twelve subpoenas for