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Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 13 of 22 of answering phones cannot be given to the media.° Similarly, Defendant fails to explain why a jury shouldn’t be allowed to consider Mr. Rizzo’s testimony about how Defendant took the passport of a 15-year-old Swedish girl and threatened her when she refused to have sex with Epstein.® And certainly a reasonable jury could reach a verdict in Ms. Giuffre’s favor based solely on Mr. Alessi’s testimony about how Defendant brought girls over for Epstein,’ or Mr. Figueroa’s testimony about how Defendant would call him to bring over underage girls, and how Defendant and Epstein would have threesomes with Ms. Giuffre.* The Court is familiar with that avalanche of mounting evidence showing sex trafficking,’ which is presumably why Defendant makes only a half-hearted effort to suggest that she has a serious summary judgment motion based on “substantial truth.” Instead, she gamely suggests that summary judgment might be proper on grounds that Ms. Giuffre is somehow a “‘libel-proof” plaintiff. DE 370 at 9. Here, too, Defendant’s argument that the facts on this issue will be so > See McCawley Decl. at Composite Exhibit 1, Johanna Sjoberg’s May 18, 2016 Dep. Tr. at 8-9, 13, 33-35, 142-143(testifying that Defendant recruited her for sex with Epstein under the guise of answering phones, a job that lasted one day, because her second day Defendant asked her to start giving massages, and it soon made it clear that Sjoberg’s purpose was to bring Epstein to orgasm so Defendant didn’t have to all of the time). °See McCawley Decl. at Composite Exhibit 2, Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52-60 (Defendant’s friend’s house manager, through tears, described how Defendant tried to force a 15 year old Swedish girl to have sex with Epstein through threats and stealing her passport) ’ See McCawley Decl. at Composite Exhibit 3, Juan Alessi’s June 1, 2016 Dep. Tr. at 28, 52-54 (Epstein’s house manager, testified that Defendant was one of the people who procured the over 100 girls he witnessed visit Epstein, and that he had to clean Defendant’s sex toys) ® See McCawley Decl. at Composite Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103 (Figueroa testified that Plaintiff told him about threesomes with Defendant and Epstein which included the use of strap-ons); and Vol. 2 at 200 (Figueroa testified that Defendant called him inquiring if he had found any other girls for Epstein) ” See, e. g., McCawley Decl. at Composite Exhibit 5, Detective Joseph Recarey’s June 21, 2016 Dep. Tr. at 29-30 (the detective who led the investigation of Epstein, testified that Defendant procured underage girls for Epstein); 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 (Epstein’s pilot testified that the passenger listed on his flight log bearing the initials - GM — was in fact Ghislaine Maxwell and Rodgers was the pilot on at least 23 of the flights in which Defendant flew with Plaintiff), etc. 13