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Case 1:15-cv-07433-LAP Document 1320-21 Filed 01/03/24 Page 9 of 15 deposition testimony — the almost the exact same number Ms. Giuffre is seeking.” Defendant cannot credibly oppose Ms. Giuffre’s additional depositions while she, herself, is trying to take more than ten without leave of court.° It is plain why Defendant does not want these depositions to go forward. Ms. Sjoberg, Mr. Alessi, and Mr. Rizzo’s testimony was harmful to Defendant’s case, and the additional depositions will provide further evidence that Defendant acted as Jeffrey Epstein’s madam, proving the truth of Ms. Giuffre’s statements that Defendant proclaimed publically as “obvious lies.” IL. MS. GIUFFRE IS SEEKING HIGHLY RELEVANT TRIAL TESTIMONY. All of the people Ms. Giuffre seeks to depose have discoverable and important information regarding the elements of Ms. Giuffre’s claims. Ms. Giuffre stated that Defendant recruited her and other young females for sex with Jeffrey Epstein. The people she now seeks to depose are all witnesses who can testify to Defendant working essentially as a madam for Jeffrey Epstein, recruiting young females for Epstein, or corroborate other important aspects of her statements. The fact that Defendant recruited girls, some of which were underage, for Epstein makes Ms. Giuffre’s claim that she was also recruited by Defendant to ultimately have sex with Epstein and others more credible — and that Defendant’s denials of any involvement in such recruiting is a bald-faced lie. Witnesses will testify that Defendant’s recruitment and management of the girls for Jeffrey Epstein was a major aspect of Defendant’s job, and that Ms. > Defendant’s counsel has taken the deposition testimony of (1) Ms. Giuffre; (2) Ms. Giuffre’s mother (Lynn Miller); (3) Ms. Giuffre’s father (Sky Roberts); and (4) Ms. Giuffre’s physician (Dr. Olson). Defendant’s counsel has noticed the following witnesses for deposition: (5) Mr. Austrich; (6) Mr. Figueroa; (7) Ms. Degorgieou; (8) a known victim of Jeffrey Epstein; (9) Mr. Weisfield; (10) Ms. Churcher; (11) Ms. Boylan; and (12) the 30(b)(6) witness for Victims Refuse Silence. fendant has. unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two of the depositions tor days when depositions of Ms. Wuftre’s witnesses have een set. 6