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Case 1:15-cv-07433-LAP Document 1325-15 Filed 01/04/24 Page 8 of 14 demonstrating that she did not start working at Mar-a-Lago until she was 17 years old --- despite her well-publicized claims that she was a “sex slave” for Jeffrey Epstein from the age of 15 years old beginning in 1998. Furthermore, testimony from other witnesses in this case, including Plaintiff's former boyfriend Tony Figueroa, materially contradict Plaintiff's claims. Mr. Figueroa testified on June 24 that he and Plaintiff were enrolled in an all-day high school and that they attended school together every day and that Plaintiff was not working for Epstein. Menninger Decl., Ex. P. Based on these newly discovered records, Mr. Figueroa confirmed that time period as October 2001 — March 2002, directly contradicting Plaintiff's deposition testimony that she was a “sex slave” for 4 years from 1998-2002 and that she was with Epstein constantly during that four year period. Based on the newly discovered education records and other witness testimony concerning those records, Ms. Maxwell should be entitled to question Plaintiff at her continued deposition about those records. Ms. Maxwell lacked those records at the time of Plaintiffs deposition because Plaintiff refused to produce her education records, Ms. Maxwell had to file a Motion to Compel and obtain a Court Order before Plaintiff would sign a release for the records. Therefore, there is no basis for Plaintiff to object to a continued deposition regarding the newly obtained records and witness testimony. E. Plaintiff identified new witnesses in her Rule 26 disclosures after her deposition Plaintiff does not address the fact that she added 28 new witnesses to her Rule 26 disclosures after her deposition. The new witnesses added by Ms. Maxwell to her Rule 26 list > The only mention Plaintiff makes is asking the Court to deny Ms. Maxwell’s motion to strike the new witnesses. Ms. Maxwell stated that her motion to strike would be by separate motion (Mot. at 10), thus there is no motion to strike.