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Case 1:15-cv-07433-LAP Document 1320-27 Filed 01/03/24 Page 9 of 15 Defendant appears to be concealing critical evidence of the sexual abuse that other witnesses have testified she possesseS. | Re Yt 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. 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 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