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Case 1:15-cv-07433-LAP Document 1325-14 Filed 01/04/24 Page 5 of 30 INTRODUCTION As more and more witnesses come forward testifying about Defendant’s involvement in the sexual abuse of young girls, Defendant’s discovery arguments have become more removed from the merits of this case and increasingly strident in their tone. The latest example of this genre is the instant motion in which the Defendant boldly proclaims that Ms. Giuffre is “playing a game of catch and release” by deliberately “withholding information” regarding her medical care. Yet the basis for these strong charges turns out to be nothing more than the fact that, when asked to produce a listing of medical care providers that Ms. Giuffre has seen in the last seventeen years — during a period of time when she lived in Australia, then Florida, then Colorado, finally returning to Australia — she was unable to recall all of the providers. Ms. Giuffre and her attorneys have worked diligently to provide this listing to Defendant and, as new information has become available, or as Ms. Giuffre has been able to recall another provider, the information has been disclosed. Indeed, Ms. Giuffre signed every medical records release that Defendant requested. There has been no deliberate “withholding” of information, much less withholding of information that would warrant the extreme sanction of precluding Ms. Giuffre from presenting her claims to a jury. Moreover, this baseless motion for sanctions comes on the heels of disturbing testimony corroborating what lies at the core of this case -Defendant was involved in facilitating the sexual abuse of young girls with Jeffrey Epstein. One witness, Rinaldo Rizzo, was in tears as he recounted Defendant bringing a 15-year-old girl to his employer’s home who, in utmost distress, told him that Defendant stole the young girl’s passport and tried to make her have sex with