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Case 1:15-cv-07433-LAP Document 1320-27 Filed 01/03/24 Page 10 of 15 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. Giuffre’s account of her sexual abuse and Defendant’s involvement accords perfectly with other witnesses’ accounts of what Defendant’s job was for Epstein.’ That other young females were similarly recruited by the Defendant is evidence that Ms. Giuffre is telling the truth about her experiences — and thus direct evidence that Defendant defamed her when calling her a liar. Clearly, if Ms. Giuffre can establish that Defendant’s modus operandi was to recruit young females for Epstein, that helps corroborate Ms. Giuffre’s own testimony that Defendant recruited her for the same purposes and in the same manner. Although the Court need not make a final ruling on this evidentiary issue now, Rule 404(b) itself makes such testimony admissible. See Fed. R. Evid. 404(b) (other act “evidence may be admissible for another purpose, such as proving motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident.”’). Indeed, even more specifically than the general provisions of Rule 404(b), Rule 415 makes these other acts admissible, due to T Defendant’s specious suggestion that Ms. Giuffre heard about the other girls whom she recruited for sexual purposes and then decided to “hop on the band wagon” (Defendant’s Resp. at 8 n.7) tacitly admits that Defendant procured a “band wagon” of girls for Jeffrey Epstein to abuse. Moreover, Defendant cannot refute the documentary evidence that she was on Epstein private jet with Ms. Giuffre over 20 times while Ms. Giuffre was a minor — flights that Defendant is, quite conveniently, now unable to recall. Motion at 5-8. 6