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Case 1:15-cv-07433-LAP Document 1330-23 Filed 01/05/24 Page 1 of 9 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. / PLAINTIFF’S REPLY IN SUPPORT OF MOTION TO REOPEN DEFENDANT’S DEPOSITION BASED ON LATE PRODUCTION OF NEW, KEY DOCUMENTS Plaintiff, Virginia Giuffre, by and through her undersigned counsel, hereby files her Reply in Support of her Motion to Reopen Defendant’s Deposition Based on Late Production of New, Key Documents. Because Ms. Giuffre has shown the importance of reopening Defendant’s deposition on these several important documents, because Defendant has not offered any substantial countervailing consideration, the Court should allow Ms. Giuffre to question Defendant in a deposition about these late produced communications. L INTRODUCTION As the Court is well aware, Ms. Giuffre has alleged that Defendant defamed her when she called her a liar after Ms. Giuffre spoke out about being a child victim of sex abuse at the hands of Defendant and Defendant’s long-time boyfriend, convicted pedophile, Jeffrey Epstein. The two documents at issue in the instant motion are Defendant’s communications with her press agent and with Epstein concerning potential statements to the media regarding Ms. Giuffre. Therefore, not only do they involve two key individuals, but also a key topic in this litigation: Defendant’s defamation of Ms. Giuffre through the media. Multiple documents show Epstein’s involvement in crafting Defendant’s various draft statements to the media concerning Ms. Giuffre, and one of the late 1