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Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 15 of 22 Further proof of malice comes from Defendant’s extraordinary lack of memory about her involvement in the abuse.'! For instance, Defendant cannot even recall a single flight on Epstein’s private jet with Ms. Giuffre, even though flight logs show that Defendant had 23 flights with Ms. Giuffre while Ms. Giuffre was underage, and Epstein’s own pilot confirmed those records.'* And Defendant cannot recall the circumstances under which a photograph was taken of her, Ms. Giuffre, and Prince Andrew — all inside Defendant’s London apartment. Based on Defendant’s convenient and near total amnesia about documented incriminating events alone, a reasonable jury could find that she acted deliberately and maliciously when she arranged for false and defamatory statements about Ms. Giuffre to be transmitted (literally) around the globe. Defendant is also less than forthcoming about the evidence that Ms. Giuffre will be able to produce at trial. Presumably recognizing that the statements her press agent (Ross Gow) released to the media were false and defamatory, Defendant states that there is “no other indicia of [Defendant] authorizing any statement [by Gow] regarding [Ms. Giuffre.” DE 370 at 10. While there are many problems with that claim, perhaps it is enough to point out that Defendant’s motion was filed on August 12, 2016 — and then, just four days later, on August 16, 2016 — defense counsel disclosed to Ms. Giuffre’s counsel an email revealing quite clearly that GIUFFRE001465; GIUFFRE001436; GIUFFRE001435; GIUFFRE001472; GIUFFRE001474; GIUFFRE001492; GIUFFRE001553; GIUFFRE001388; GIUFFRE001555; GIUFFRE001556; GIUFFRE001557; GIUFFRE001392; GIUFFRE001526; GIUFFRE001530; GIUFFRE001568; GIUFFRE001536; GIUFFRE001538; GIUFFRE001541; GIUFFRE001546; GIUFFRE001399; GIUFFRE001402; GIUFFRE001405; GIUFFRE001406; GIUFFRE001449; GIUFFRE001409; GIUFFRE001410; GIUFFRE001411; GIUFFRE00; etc.); See McCawley Dec. at Sealed Composite Exhibit 4 Figueroa Dep. Tr. at page 200:5-12 (Defendant called him to bring girls and he brought 16 and 17 year olds). tt See, e.g., McCawley Dec. at Exhibit 7, Maxwell’s April 22, 2016 Dep. Tr. at 78-79, 144 (barely recollects Plaintiff at all); see also McCawley Decl. at Exhibit 6, Excerpted Rodgers Dep. Ex. | (flight records evidencing Defendant (GM) flying with Ms. Giuffre ”? See McCawley Dec. at Sealed Composite Exhibit 5, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36; see also Exhibit 6, Excerpted Rodgers Dep. Ex. | at flight #s 1433-1434, 1444-1446, 1464-1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589. 15