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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 26 of 27 fabrication. This is part of an overarching plan by Ms. Giuffre’s lawyers to cherry-pick the evidence they want to publically reveal while using this Court’s powers to suppress evidence damaging to them. There is a further irony as well, which is that the entire basis of Ms. Giuffre’s participation in the CVRA Action was a complaint that the Government unlawfully kept secret the details of her alleged victimization at Mr. Epstein’s hands. Yet it is now Ms. Giuffre and her lawyers who are seeking to keep secret the whole truth about Ms. Giuffre’s story.'? 62. I believe that the law and basic notion of fairness should permit me to prove the whole truth, namely, that Ms. Giuffre never accused me of misconduct until 2014, and that her belated complaint against me is, as I have always said, a fabrication from start to finish. The Requested Documents help prove those critical points. This Court ought not allow itself to be a tool of secrecy used by Ms. Giuffre and her lawyers to keep the whole truth from coming out. '8 As described in my opening Declaration, Ms. Giuffre’s legal assault on me, conducted through her lawyers at Boies Schiller & Flexner LLP (“BSF”), continues in the form of a motion for sanctions in Florida state court. There, she claims that I violated a court order in the Edwards defamation lawsuit by testifying truthfully in a deposition about discussions that I had had with David Boies. Prior to my testimony, my lawyers submitted an affidavit from me to the Florida court describing these discussions, and the Florida judge sealed the affidavit. He did not direct that I refrain from testifying about the matter, nor did he sanction me for disclosing the discussion in an affidavit, as Ms. Giuffre’s lawyers requested. When asked whether he was making a ruling on the BSF motion for sanctions regarding the content of the affidavit, Judge Lynch replied “No. I’m just sealing these [the affidavit] because I think they should be sealed.” Ex. X at 24 (Transcript of Emergency Motion to Seal, December 18, 2015). Thus, contrary to the later motion for sanctions, there was no “gag order” placed in me when the affidavit was submitted, nor did I violate any court order by truthfully answering a question put to me by the opposing lawyer and offering to seal my answer. The BSF motion for sanctions was subsequently dismissed for lack of jurisdiction and standing, and is now being appealed by Ms. Giuffre. 26