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Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 12 of 22 general timing of financial disclosures is concerned, plaintiffs need not wait until after a finding of liability or a preliminary finding of damages to obtain discoverable financial information from defendants.” Jd. Those conclusions were well-reasoned then, and remain well-reasoned now. Just as the Court refused to deny pretrial financial discovery to the plaintiff in that case, it should not deny Ms. Giuffre pretrial financial discovery here. Pre-trial discovery is the only way to ensure that Ms. Giuffre will be able to discover all the information that she needs for each of the three purposes outlined in Part I above. B. Discovery of Financial Information Should Not Be Delayed until a Ruling on Defendant’s Summary Judgment Motion. Defendant also tries to interpose one last stalling argument: That discovery of financial information should await a ruling on her anticipated summary judgment motion. This argument should be rejected for two reasons: First, any argument that Defendant might advance in a summary judgment motion would border on frivolous given the overwhelming evidence establishing her involvement in sex trafficking. Second, because the trial is drawing near, waiting for summary judgment motions to be decided would unreasonably compress the time available to Ms. Giuffre’s counsel to investigate Defendant’s financial information. Defendant anticipates that she will “likely” file a summary judgment motion which will include an argument concerning the “substantial truth” of Defendant’s statements. DE 370 at 9. The Court will notice that even Defendant herself is not prepared to write that she will be able to prove the truth of her statements — inserting the qualifying word “substantial” in front of the word “truth,” presumably, because of the avalanche of evidence showing her deep involvement in Epstein’s sex trafficking. Defendant does not explain, for instance, how she will argue that the Court should grant summary judgment rather than allow the jury to hear Ms. Sjoberg’s testimony of how Defendant lured her from her school to have sex with Epstein under the guise 12