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Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 5 of 22 on a published article from the New York Post, it appears that Defendant’s townhouse (among other assets) might be part of a covert payoff from Epstein to Defendant. As the Post reports, “Ta] lawyer with links to Epstein reportedly bought the townhouse for Maxwell, who has allegedly never earned enough or inherited enough to make the purchase on her own.” http://nypost.com/2016/04/28/alleged-epstein-madam-sells-16m-manhattan-townhouse/. This article suggests that Defendant is reliant upon Epstein for tremendous financial support, which certainly provides a strong motive for her to provide favors to Epstein — including providing him with underage girls for sex. It also provides a strong motive for her to lie at trial about Epstein’s (and her own) sex trafficking. Indeed, to conceal these facts, other media reports suggest that the reason that Defendant was trying to sell her townhouse “quietly” was perhaps “to put some distance between herself and Epstein, who owns a mansion a few blocks away.” http://pagesix.com/2015/02/02/accused-epstein-madam-quietly-selling-ues-townhouse/. Again, perhaps there is some innocent explanation for these secretive efforts. But, if so, Defendant has declined to provide it. See id. (noting Defendant’s “rep didn’t comment”). Cc. Discovery of Financial Information is Relevant to the Issue of the Size of any Punitive Damages. Financial information regarding Defendant is also highly relevant to Ms. Giuffre’s punitive damages claim. Of course, it is well-settled law that “evidence of a tortfeasor’s wealth is traditionally admissible as a measure of the amount of punitive damages that should be awarded.” City of Newport v. Fact Concerts, Inc., 453 U.S. 247, 270 (1981). As explained by the Reporters of the American Law Institute’s Restatement of Torts, when considering the size of punitive damages “[t]he wealth of the defendant is also relevant, since the purposes of exemplary damages are to punish for a past event and to prevent future offenses, and the degree of