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Case 1:15-cv-07433-LAP Document 1328-35 Filed 01/05/24 Page 2 of 10 Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this Motion for Leave to File a Sur- Reply or, Alternatively, to Strike Plaintiff's Misrepresentations of Fact from her Reply In Support of Motion For Protective Order And To Direct The Defendant To Disclose All Individuals To Whom Defendant Has Disseminated (sic) Confidential Information (Doc. #388), and states as follows: INTRODUCTION Plaintiff's Reply makes material misrepresentations of fact. Those misstatements cannot stand in a filed, albeit redacted, pleading. Ms. Maxwell has never “admitted” to having “threesomes with multiple different girls.” (Reply at 4). That is a misstatement of fact compounded by Plaintiffs intentional omission of the previous page of deposition testimony which exposes the falsehood. Similarly, Detective Joe Recarey never “testified that Defendant procured underage girls for Epstein.” (Reply at 4) To the contrary, he testified that a// of the underage girls he interviewed never mentioned Ms. Maxwell at all. These are but a few of the misrepresentations of fact contained in Plaintiff's Reply. Accordingly, Ms. Maxwell seeks leave of the Court to file a Sur-Reply or, alternatively, moves the Court to strike from Plaintiffs Reply the misstatements of fact. PLAINTIFF’S MISSTATEMENTS OF FACT 1. “Defendant's own admission of how she and Epstein had threesomes with multiple different girls whose names she can’t even remember...” (Reply at 4). Ms. Maxwell testified that on a “few occasions” she engaged in sexual activity with Jeffrey Epstein and another adult woman. Specifically, when asked to describe the woman, Ms. Maxwell testified: Q. Can you describe any of the people with whom you engaged in sexual activities at Mr. Epstein's home in Palm Beach? A. The description that I have is somebody who is roughly my age, and I recall a blond and I recall a brunette, and that's pretty much what I recall. 1