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Case 1:15-cv-07433-LAP Document 1320-21 Filed 01/03/24 Page 13 of 15 An additional reason this motion is appropriate now is that, despite Ms. Giuffre’s diligent pursuit of depositions, many witnesses have cancelled their dates, failed to appear, or wrongfully evaded service. These maneuvers have frustrated Ms. Giuffre’s ability to take their depositions in a logical and sequential fashion, complicating the planning of a deposition schedule. For example, on April 11, 2016, Ms. Giuffre served notice on Defendant’s counsel for the deposition of Rinaldo Rizzo, setting it for May 13, 2016. Nearly a month later, just a few days before that properly noticed deposition, Defendant’s counsel requested that it be rescheduled, and, therefore, that deposition did not take place until June 10, 2016. Additionally, three other important witnesses evaded Ms. Giuffre’s repeated efforts to serve them. It took Ms. Giuffre’s motion for alternative service (DE 160) to convince Jeffrey Epstein to allow his attorney to accept service of process. The Court also has before it Ms. Giuffre’s motion to serve Sarah Kellen and Nadia Marcinkova by alternative service. These witnesses’ evasion of service delayed the taking of their depositions, and, as of the date of this filing, none have been deposed yet. CONCLUSION For all these reasons, Ms. Giuffre should be allowed to take three more depositions than the presumptive ten deposition limit — a total of thirteen depositions. Dated: June 13, 2016. Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 10