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Case 1:20-cr-00330-PAE Document 208 Filed 04/16/21 Page 9of16 The defamation litigation was legally very complicated and New York law afforded many statutory, common law, and constitutional defenses to Ms. Maxwell (which may become relevant at another time). In addition to strong legal defenses Ms. Maxwell’s defense of truth was exceptional. It was clear that given the wording of Mr. Gow’s statement, proof of falsity of one or more of Giuffre’s claims would be enough to defeat the civil action. Very quickly there were many provable “obvious lies.” A few examples: e Contrary to her claim of “slavery,” Giuffre lived independently from her parents with her fiancé long before meeting Epstein or Ms. Maxwell and held a number of jobs in 2001 and 2002. e Giuffre’s employment at the Mar-a-Lago spa began in fall 2000 when she was 17, not 15. (This falsity was important to Giuffre’s story for many reasons.) e Palm Beach Police investigation revealed no evidence that Ms. Maxwell was involved in sexual abuse of minors, sexual trafficking or production or possession of child pornography. e No nude photograph of Giuffre was displayed in Epstein’s home. e Giuffre’s tales about foreign presidents and prime ministers were untrue. e All of the famous people Giuffre claimed to have been sexually trafficked to denied these claims, which were completely implausible. Importantly, Giuffre post-dates the allegations contained in the superseding indictment (“Indictment”) by three years. By her claims, and admissions, she did not meet Epstein until 2000, long after the accusers named in the Indictment. Her strong connection with these accusers developed through her lawyers who likely represent at least two of the accusers and some of the witnesses. Virtually every issue in the defamation action was contested. A review of the docket, unfortunately, reflects over one-thousand entries. The parties disagreed about the scope and meaning of virtually all of Judge Sweet’s discovery orders, including those related to Ms. Maxwell’s depositions. Significantly, Judge Sweet’s Order prefaced all the listed categories with the words “sexual activity” an “sexual activities.” DOJ-OGR-00003717