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Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 3 of 22 Defendant, “the daughter of the late disgraced press baron Robert Maxwell, has sold her townhouse at 116 E. 65" St. for $15 million.” See http://nypost.com/2016/04/28/alleged-epstein- madam-sells-16m-manhattan-townhouse/. When questioned about the sale, Defendant’s representative refused to comment. See id. (broker Shari Scharfer Rollins, of Douglas Elliman, did not return calls). The transfers of assets, likely out of the jurisdiction of this Court, provides evidence of consciousness of criminal guilt and civil liability. Clearly, Ms. Giuffre is entitled to explore all the circumstances surrounding the timing and consummation of this sale, including whether Defendant has now secreted these assets someplace where they may be difficult to reach, such as in the United Kingdom (where, on information and belief, Maxwell is a UK citizen holding a UK passport) or elsewhere. Maxwell’s removal and apparent concealment of assets takes place against a backdrop of disregard of court orders by Maxwell and others involved in the Epstein sex trafficking organization. In 2009, before suit was ever filed in this case, Maxwell was served with a subpoena for a deposition in a civil case against Jeffrey Epstein. After extensive discussion and coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality agreement prepared by Maxwell’s attorney, at the eleventh hour Maxwell’s attorney informed plaintiff's counsel that Maxwell’s mother was very ill and that consequently Maxwell was leaving the country with no plans to return. The deposition was cancelled. Yet a short time later, Maxwell was photographed at Chelsea Clinton’s wedding in Rhinebeck, New York, confirming the suspicion that she was indeed still in the country and willing to say anything to avoid her deposition. Similarly, the Court is familiar with the long (and still on-going) effort of Ms. Giuffre’s efforts to take the depositions of those who participated with Defendant in sexual abuse -- 3