Giuffre_Maxwell_Batch4_p00162.png

Case 1:15-cv-07433-LAP Document 1328-7 Filed 01/05/24 Page 1 of 12 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. / PLAINTIFF’S REPLY IN SUPPORT OF MOTION TO ENFORCE THE COURT’S ORDER AND DIRECT DEFENDANT TO ANSWER DEPOSITION QUESTIONS Plaintiff, Virginia Giuffre, by and through her undersigned counsel, files this Reply in Support of her Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions. Defendant argued that Mr. Boies’ questions were outside this Court’s Order. That is simply untrue. Defendant refused to answer questions that go to heart of the type of questions this Court specifically ordered Defendant to answer: they could not be more on-point. None of Defendant’s arguments change the language of this Court’s Order. None of Defendant’s arguments change the questions Defendant refused to answer. Accordingly, Ms. Giuffre’s motion should be granted. I. PRELIMINARY STATEMENT Defendant begins her brief with snippets of her self-serving testimony. As the Court is aware, all of this testimony is directly contradicted by the myriad of other witnesses in this case who have testified at deposition, including Defendant’s own witness, Tony Figueroa. Defendant has claimed in her deposition that she did not procure girls for sex with Epstein nor notice the