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Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 16 of 22 Defendant and Gow had been coordinating the attacks on Ms. Giuffre. In November 10, 2015, after this defamation suit was filed, Defendant continued to use Gow as her press agent, as demonstrated in her email addressed to “Ghislaine [Maxwell] and Philip [Barden, attorney for Maxwell]”, Gow forwarded a press inquiry from the New York Times and then asked “[p]lease advise how you wish to respond.” See McCawley Dec. at Exhibit 8. In addition, since Defendant filed the instant motion, Ms. Giuffre has discovered an article that refers to a yet another of Defendant’s defamatory statements, not previously known to Ms. Giuffre. It is quoted in an article from The Sun (online), titled: “Prince Andrew’s pal Ghislaine ‘groped teen girls,’” located at https://www.thesun.co.uk/archives/news/6754/prince-andrews-pal-ghislaine-groped- teen-girls/. Presumably, if further evidence of the linkages between Defendant and her press agent are required, those will be established during the deposition of Gow — which likely explains why Defendant has refused to make her press agent available for deposition, forcing Ms. Giuffre to resort to the Hague Convention to try to obtain his testimony. See DE 358, this Court’s Issuance of a Letter Rogatory. Finally, waiting until any summary judgment is decided will effectively make it impossible for Ms. Giuffre to investigate financial issues. As things stand now, summary judgment motions must be filed by October 28, 2016. Given the ordinary time required for a response and a reply — and then a further decision by this Court — very little time would remain for the Ms. Giuffre to evaluate and investigate any financial information that might be provided by Defendant at that time. Clearly, the better approach is to allow that discovery now. See, e.g., Munoz v. Manhattan Club Timeshare Ass'n, Inc., No. 11-CV-7037 JPO, 2012 WL 479429, at *2 (S.D.N.Y. Feb. 8, 2012). 16