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Case 1:15-cv-07433-LAP Document 1328-7 Filed 01/05/24 Page 4 of 12 Both Sarah Kellen and Nadia Marcinkova invoked the Fifth Amendment when asked about Defendant trafficking girls’ in a previous action, and both failed to show up for their depositions in this case. Also in a previous action, Alfredo Rodriguez, another house manager, testified that Defendant “knew what was going on” with the underage girls, and threatened him about telling others.’ Tellingly, Defendant has not been able to procure a single witness - not one - who can testify that Defendant did not procure girls for sex with Epstein and did not participate in the sex. Even one of her own witnesses, Tony Figueroa, testified that she both procured girls and participated in the sex. Indeed, those who knew her well, who spent considerable time in her and Epstein’s shared household, have testified that she was Epstein’s procuress. With every deposition taken, the chorus of voices accusing Defendant of being a procurer of girls for Epstein grows louder and stronger, corroborating Ms. Giuffre’s account, and proving that Defendant defamed her when she called her a liar.'* In her Response brief, Defendant puts forth the number of questions posed to her in her deposition; however, the important number is omitted: how many questions she actually answered. What Defendant fails to tell the Court is how many questions - and how much deposition time - was taken up by Defendant engaging in improper behavior. Defendant spent much of her time refusing to answer basic questions so that they had to be repeated multiple » See McCawley Decl. at Exhibits 14-15, Sarah Kellen’s March 24, 2010 Dep. Tr. at 37-40, 100; and Nadia Marcinkova’s April 13, 2010 Dep. Tr. at 29-35, 47-49. 8 See McCawley Decl. at Exhibit 16, Alfredo Rodriguez’ July 29, 2009 Dep. Tr. at 176-177; 169-172. 4 Defendant claims that “Plaintiff's 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.” This is simply untrue. 4