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Case 1:15-cv-07433-LAP Document 1320-24 Filed 01/03/24 Page 9 of 16 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 have testified she possesses. For example, Mr. Alessi testified that Defendant kept a large book of naked photos that she took of young girls. 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 > See McCawley Decl. at Exhibit 2, Rizzo *Final Dep. Tr. “Q. So in the house, tell me if Iam wrong, you have Jeffrey Epstein, Ghislaine Maxwell and approximately 11 girls? A. Yes, somewhere between 11 and 12. Q. Can you describe the 11 to 12 girls to your memory? A. In my recollection, various of ages. They could have been from as young as 14, 15 to 18 maybe, 19... very girlish.” *32:8-24; “Q. Once inside the house, what happens next? A. I showed Ghislaine and Jeffrey into the living room, and Ghislaine was the one that instructed the girls, pointing that they needed to come to the living room.” *34:5-10. “Q. What happens next? A. . . . it was getting very perogative [sic], nothing I would want my children to see. The girls were grinding on each other, lifting up their tops, it was very inappropriate.” *37:11-38:6. “Q. What did you see next? A... . From what I knew, Jeffrey was with Ghislaine and now I have all these girls acting very inappropriate ....” *38:22-39:7. “Q. When the girls are kissing either Jeff or other girls where was Ghislaine Maxwell? A. Sitting right next to Jeffrey.” *40:24-41:3. “Q. Is there something you remember vividly? A... . I did pull the nanny aside and I was really, my wife and I were dumbfounded, profound of the situation, and she mentioned this was an occurrence that had happened before, and they called it the kissing game.” *41:8-17.” 5