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Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 3 of 27 Defendant Ghislaine Maxwell, by and through her counsel, hereby submits the following Response in Opposition (“Response”) to Plaintiff's Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions Filed Under Seal (“Motion”), as follows: INTRODUCTION This lawsuit presents one relatively simple question: is Plaintiff's claim that she was sexually abused, sexually trafficked and held as a “sex slave” by Jeffrey Epstein between 1999 and 2002 “with the assistance and participation of’ Ms. Maxwell substantially true? Plaintiff already has admitted, under oath, that substantial portions of her story are untrue; she has so far refused to say under oath what other lies printed by the press about her story are untrue, but has admitted that journalist Sharon Churcher “got it wrong.” For example, Plaintiff has admitted that she did not meet Ms. Maxwell or Mr. Epstein in 1999 (or in 1998) at the age of 14 or 15, as she previously has sworn and as she told members of the press. Declaration of Jeffrey S. Pagliuca “Pagliuca Decl.”), Composite Ex. A (Testimony of Plaintiff Virginia Giuffre on May 3, 2016), at 26-27, 220-226. Plaintiff admitted that she did not spend her sweet 16" birthday with Mr. Epstein and Ms. Maxwell as she included in her book manuscript, her Jane Doe #102 Complaint and in the story she sold to the Daily Mail. Jd. at 102. Plaintiffs counsel has admitted that it was a mistake to sue Alan Dershowitz for defamation, after he provided them documentation establishing he never was in their client’s presence, nor did he have sex with her. Pagliuca Decl., Ex. B. And Plaintiffs story about attending a dinner party with Bill Clinton on Little St. James was debunked by none other than former FBI head, Louis Freeh. /d. Yet, undeterred, Plaintiff and her counsel continue to use this lawsuit to seek discovery of matters far afield of the one simple question posed in the defamation claim, to explore events that occurred well past 2002, when Plaintiff lived in Australia and had no contact with Ms. Maxwell or Mr. Epstein. The current witch-hunt has now expanded into the private personal life 1