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Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 2 of 22 financial information from just the time during which Defendant has defamed Ms. Giuffre (2015 to present). As with most of the other discovery requests she has received, Defendant has chosen not to produce any information. Instead, she has filed this motion for a blanket protective order, arguing that financial discovery has no relevance whatsoever to any issue in this case. Of course, given the broad scope of discovery, the Court can grant Defendant’s motion only if no relevance exists at all. But in fact, Defendant’s financial information is highly relevant to at least three issues in this case. First, Defendant’s recent efforts to conceal assets from the reach of this Court proves consciousness of her guilt of sex trafficking. Second, Defendant’s financial affairs will show dependence on Epstein for financial support, an issue highly relevant to motive.” Third, as Defendant herself appears to admit, the discovery is relevant to the size of the punitive damage award that the jury should enter in this case. Facts relevant to each of these three points are set out in order below. A. Discovery of Financial Information is Relevant to Show Defendant’s Transfer of Assets Out of the Jurisdiction after the Commencement of Litigation and thus Her Consciousness of Guilt. The requested financial information is relevant to issues relating to Defendant’s apparent attempt to conceal assets from the Court. The timing of recent events is telling here. As the Court will recall, in court pleadings filed December 30, 2014, Ms. Giuffre initially publicly alleged Defendant had sexually abused her. On September 21, 2015, Ms. Giuffre filed her lawsuit against Defendant here in the Southern District of New York. (DE 1.) Ms. Giuffre is seeking at least $50 million in compensatory and punitive damages from Ms. Maxwell. Just a few months after the suit was filed, on April 28, 2016, the New York Post reported that ? As recently as 2005, Defendant was on Epstein’s Palm Beach House bank account for Palm Beach. Bates Number SAO FOIA disc 7 (bates Giuffre 007590) at p. 93-95. 2