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Case 1:15-cv-07433-LAP Document 1330-23 Filed 01/05/24 Page 3 of 9 attempted to solicit Defendant’s testimony pursuant to the Court’s Order, but Defendant defied that Order and again refused to answer many questions, thus requiring Ms. Giuffre to file the Motion to Enforce the Court’s Order, to attempt to obtain another deposition with a stern direction from the Court to the Defendant that she must answer questions during her deposition as originally directed by this Court. That motion is currently pending before this Court (DE3 14/356). Thereafter, in this case where Defendant’s production of email communications has been miniscule, Defendant stated that she “inadvertently” failed to produce two critical emails, and produced them after Defendant’s second deposition was complete. While Ms. Giuffre attempted to confer with Defendant to secure her agreement to be deposed on this new information, Defendant refused to sit for a follow up deposition (despite the fact that Ms. Giuffre agreed to sit for her deposition under these same circumstance), thereby forcing Ms. Giuffre to file this motion with the Court to secure the Defendant’s deposition on these two e-mails. Defendant’s paltry justification for opposing Ms. Giuffre’s motion is that she previously answered questions concerning certain other communications with Epstein and Gow. That argument is unavailing. First, Ms. Giuffre is entitled to question the Defendant on these specific communications. One is an email chain with her joint defense partner Jeffrey Epstein, who was also a co-abuser with her. The other is a communication with Ross Gow, Defendant’s press agent who she refused to produce for a deposition, despite him being her agent and despite their sharing the same attorney, forcing Ms. Giuffre to litigate the issue in the London courts, against Defendant’s counsel, and at significant expense. An English Court has since ordered Gow to sit for his deposition, despite Defendant and her counsel’s obstructionist refusal to produce him prior to that litigation. Second, these documents are relevant precisely for the reason Defendant attempts to say they are not: their date. Notably, the questioning that Defendant cites in her brief surrounds