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Case 1:15-cv-07433-LAP Document 1320-24 Filed 01/03/24 Page 8 of 16 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 * See McCawley Decl. at Exhibit 2, Rizzo *Final Dep. Tr. *52:6-7; *55:23-57:23. “Q. How old was this girl? A. 15 years old.” “What did she say? A. She proceeds to tell my wife and I that, and this is not — this is blurting out, not a conversation like I’m having a casual conversation, that quickly I was on an island, I was on the island and there was Ghislaine, there was Sarah, she said they asked me for sex, I said no. .. . And she says no, and she says Ghislaine took my passport. And I said what, and she says Sarah took her passport and phone and gave it to Ghislaine Maxwell, and at that point she said that she was threatened. And I said threatened? She says yes, I was threatened by Ghislaine not to discuss this. .. And she said that before she got there, she was threatened again by Jeffrey and Ghislaine not to talk about what I had mentioned earlier, about — again, the word she used was sex. Q. And during this time that you’re saying she is rambling, is her demeanor continues to be what you described it? A. Yes. Q. Was she in fear? A. Yes”.