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Case 1:15-cv-07433-LAP Document 1320-21 Filed 01/03/24 Page 7 of 15 Second, if Ms. Giuffre is denied these depositions, she will not have had the opportunity to obtain the information by other discovery in this case. The Court will recall from Ms. Giuffre’s opening motion that Defendant’s surprising lack of memory has, in no small part, caused the need for additional depositions. See Motion at 5-8 (listing 59 examples of memory lapses during Ms. Maxwell deposition, including inability to remember events recorded on aircraft flight logs or a photograph). Defendant offers no explanation for her convenient forgetfulness. Moreover, evidence of being recruited by Defendant and being sexually assaulted is not something Ms. Giuffre can obtain through requests for production or through interrogatories. The only way of obtaining such evidence is from witness testimony by those who were victimized, those who assisted Defendant in recruiting and abuse, and those who observed the recruiting or the abuse. For example, Rinaldo Rizzo, an estate manager for a friend of Defendant and Epstein’s, testified about an episode where Defendant had threatened a terrified 15 year old girl and confiscated her passport to try to make her have sex with Epstein on his private island: See McCawley Decl. at Exhibit 2, Rizzo Deposition * Mr. Rizzo testified about another episode where Defendant gave instructions to, and presided over, a group of eleven girls