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Case 1:15-cv-07433-LAP Document 1320-27 Filed 01/03/24 Page 11 of 15 the fact that those involved in sexual abuse of minors have a strong propensity for repeating those crimes. See Fed. R. Evid. 415(a)( (“In a civil case involving a claim for relief based on a party’s alleged sexual assault or child molestation, the court may admit evidence that the party committed any other sexual assault or child molestation.”). Entirely apart from corroborating Ms. Giuffre’s own individual abuse, however, Defendant fails to recognize that in calling Ms. Giuffre a “liar”, she was attacking all aspects of Ms. Giuffre’s account — including Ms. Giuffre’s statements that Defendant served generally as a recruiter of girls for Epstein and that Epstein sexually abused the underage girls that were brought to him. Thus, in this defamation case, the testimony of these witnesses are admissible not only to bolster Ms. Giuffre’s testimony about her individual abuse, but because they are simply part of the body of statements whose truth or falsity is at issue in this case. In addition, one of the witnesses that Ms. Giuffre seeks to depose is registered sex offender Jeffrey Epstein, who stands at the center of the case. Indeed, some of the most critical events took place in the presence of just three people: Ms. Giuffre, defendant Maxwell, and Epstein. If Epstein were to tell the truth, his testimony would fully confirm Ms. Giuffre’s account of her sexual abuse. Epstein, however, may well attempt to support Defendant by invoking the Fifth Amendment to avoid answering questions about his sexual abuse of Ms. Giuffre. Apparently privy to her former boyfriend Epstein’s anticipated plans in this regard,* Defendant makes the claim that it would be a “convoluted argument” to allow Ms. Giuffre to use those invocations against her. Defendant’s Resp. at 3. Tellingly, Defendant’s response brief cites no authority to refute that proposition that adverse inference can be drawn against co- conspirators. Presumably this is because, as recounted in Ms. Giuffre’s opening brief (at pp. 20- Tn discovery, Defendant Maxwell has produced several emails between Epstein and herself discussing Ms. Giuffre.