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Case 1:15-cv-07433-LAP Document 1320-28 Filed 01/03/24 Page 12 of 32 President Clinton being flown in a helicopter by Ghislaine Maxwell, the relevance of any testimony he might add (i.e., confirm that he was, as Louis Freeh determined, never on the Island) is non-existent. The only purpose for seeking this deposition is for the calculated media strategy that Plaintiff and her publicity-seeking attorneys have devised. Plaintiff failed to disclose President Clinton as a witness until June 1, failed to notice his deposition, failed to diligently pursue a subpoena on him and he has no relevant testimony to offer. Accordingly, Plaintiff's leave to modify the scheduling order to permit his deposition should be denied. B. Ross Gow As the Court likely recalls, Ross Gow actually issued the statement pertinent to this defamation suit. Plaintiff has known about Ross Gow and his role in this lawsuit since the outset: She referenced him repeatedly by name in the Complaint filed on September 21, 2015. See, e.g., Complaint paragraph 29 (“As part of Maxwell’s campaign, she directed her agent, Ross Gow, to attack Giuffre’s honesty and truthfulness and to accuse Giuffre of lying.”). Plaintiff also has been well aware throughout that Mr. Gow resides in London. See, e.g., Plaintiff's Motion to Compel Improper Privileges, at 8 (Doc. #33). After filing that Complaint in September and litigating the Motion to Compel based on privileges related to Mr. Gow in March, Plaintiff took exactly zero steps to depose Mr. Gow until she filed this Motion. Now, nine months after filing her Complaint, Plaintiff contends there is “not sufficient time” for her to “go through the Hague Convention for service on Mr. Gow” so as to “complete this process before the June 30, 2016 deadline.” Mot. at 4. Indeed, Plaintiff only initiated that process three days ago, on Friday, June 17, two weeks shy of the discovery cut-off. Plaintiff, once again, tries to blame Ms. Maxwell for her own lack of diligence by misrepresenting to this Court that “Ms. Giuffre asked that Defendant produce her agent, Mr. 9