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Case 1:15-cv-07433-LAP Document 1325-7 Filed 01/04/24 Page 6 of 30 HEY A nother witness, Joanna Sjoberg, testified that Defendant recruited her from her school campus to have sex with Epstein with lies about being her personal assistant.’ Two other witnesses, one an underage victim i) and the other, the police detective who ultimately ended up investigating Epstein (Detective Joseph Recarey, Retired), gave testimony about how Epstein used other women to recruit minors to have sex with him.* Most recently, a witness testified that Defendant would call him and ask him to bring over young girls that she would provide to Epstein. See McCawley Decl. at Exhibit 9, ROUGH Deposition Transcript of Tony Figueroa at 162:8-19. It is against this backdrop that Defendant has filed a motion seeking sanctions. The motion is a transparent effort to deflect attention from the merits of Ms. Giuffre’s claim by inventing “willful” discovery violations and should be rejected in its entirety. FACTUAL BACKGROUND L MEDICAL PROVIDER IDENTITIES As the Court is aware, Defendant has requested that Ms. Giuffre provide the names and medical records of every medical provider she has ever had, for any type of treatment, since 1999. This would be no easy task for anyone, and Ms. Giuffre has had many medical providers ' See McCawley Decl. at Exhibit 1, Excerpts from the June 10, 2016 Deposition of Rinaldo Rizzo. Id. > See McCawley Decl. at Exhibit 2, Excerpts from the May 18, 2016 Deposition of Joanna Sjoberg. * See McCawley Decl. at Exhibits 3 and 4, Excerpts from the June 20, 2016 Deposition of and Excerpts from the June 21, 2016 Deposition of Joseph Recarey. 2