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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 11 of 27 23. It is inconceivable that Ms. Giuffre could have forgotten about having sex with a man she described in such detail in her Manuscript. She either lied for money in her Manuscript, or committed perjury in her deposition. 24. The same Manuscript that names | and describes a sexual encounter with him in great detail does not mention me as someone with whom she claims to have had sex. To the contrary, it mentions me only as someone who had a discussion with Mr. Epstein in his bedroom after he had had sex with Ms. Giuffre. See Dershowitz Decl., § 37. This entirely fabricated story was obviously inserted as the result of the email exchange between Ms. Giuffre and Sharon Churcher in which Ms. Churcher urges Ms. Giuffre to include my name in her manuscript in order to make it more marketable. See Dershowitz Decl., § 35. It is imperative for me to be able to use those currently-sealed documents—the Emails and the Manuscript in particular—to refute the false allegations against me that have been repeated in public filings in this case, and to support the truth, i.e., that Ms. Giuffre never accused me prior to the CVRA Action. Indeed, because they show that the story about me is of very recent vintage, such documents corroborate the information provided to me by Ms. Giuffre’s best and oldest friend: namely that Ms. Giuffre had never accused me of having had sex with her until she felt pressured to do so by her lawyers. This point—that her accusation against me is a recent fabrication—is central to my defense against the false charges that the lawyers in this case continue to level against me, and I have a right to be able to respond to them by self-proving documents. 25. Ms. Giuffre has also claimed to have had sex with such prominent individuals as fone i es former Governor of New Mexico Bill Richardson, the late renowned M.1.T professor Marvin Minsky, the chairman of the Hyatt Corporation Tom Pritzker, the former Prime Minister of Israel Ehud 11