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Case 1:15-cv-07433-LAP Document 1320-28 Filed 01/03/24 Page 21 of 32 These correspondences demonstrate that Ms. Maxwell has no control over Mr. Epstein in regards to the alleged defamation statement, he had no role in issuance of the statement, he has no benefit in the outcome of this litigation and he played no controlling role in its respect. Similarly, there is not any evidence at all to support an adverse inference to be drawn from either Sarah Kellen nor Nadia Marcincova’s assertion of the Fifth. Ms. Maxwell hardly knows either woman, never worked with them, they have had nothing to do with this litigation and do not stand to benefit from it, especially as Plaintiff has never made any allegations about her involvement with either of the two of them, they are simply irrelevant to this defamation action. I. PLAINTIFF’S BAD FAITH DISCOVERY TACTICS SHOULD NOT BE REWARDED WITH EXTRA TIME 1. Plaintiff’s Rule 26 Revolving Door Plaintiff's army of lawyers (who collectively have been litigating matters related to Jeffrey Epstein since 2008) served their Rule 26 initial disclosures on November 11, 2015. Those disclosures listed 94 individual witnesses with knowledge regarding the facts of this case, yet provided addresses (only of their counsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categories of witnesses such as “all other then-minor girls, whose identities Plaintiff will attempt to determine” and “all pilots, chauffeurs, chefs, and other employees of’ Ms. Maxwell or Jeffrey Epstein. Plaintiff claimed as to her Rule 26 disclosures that “only a fraction of those individuals will actually be witnesses in this case, and as discovery progresses, the list will be further narrowed.” (Doc. #20 at 17) The opposite has happened. Between November 11 and March 11, Plaintiff trimmed her Rule 26 list of persons with knowledge from 94 to 69, inexplicably removing 34 names, but adding 12 more. She removed, 18