Giuffre_Maxwell_Batch5_p00322.png

Case 1:15-cv-07433-LAP Document 1330-23 Filed 01/05/24 Page 2 of 9 produced documents at issue in this pending motion is an email chain showing Epstein’s involvement in crafting yet another draft statement. The other late produced document is a communication between Defendant and her press agent, Ross Gow. It also concerns a potential statement to the media about Ms. Giuffre. This email shows Gow’s continued involvement in handling press inquiries concerning Ms. Giuffre on Defendant’s behalf. That is relevant to Ms. Giuffre’s claims for multiple reasons, not least of which is Defendant’s nonsensical attempts to distance herself from Gow’s statement, as recounted in the moving brief. Her continuance of working with him after he issued the defamatory statement, and after the commencement of this litigation (as shown by the document at issue) is evidence to the contrary. Ms. Giuffre should be able to cross her with that email and ask related questions. Therefore, both of these documents are highly relevant. Whatever Defendant argues about her prior deposition, she cannot claim that she was questioned about these two emails. Ms. Giuffre deserves the opportunity to ask Defendant about them. I. ARGUMENT A. Discovery Concerning These Emails is Not Duplicative, and it is Highly Relevant As the Court will recall, a Defendant’s initial deposition, she answered the questions put to her with evasive, non-responsive answers, unqualified refusals to answer, feigned memory loss, and feigned ignorance over the meaning of basic sentences and basic words (“I don’t know what you mean by puppet”). As a result, Ms. Giuffre was forced to file a Motion to Compel Defendant to Answer Deposition Questions (DE 143). On June 20, 2016, this Court granted Ms. Giuffre’s Motion and directed Defendant to sit again for her deposition (June 20, 2016 Sealed Order, filed in redacted form at DE 264-1). As recounted in Ms. Giuffre’s Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions (DE 314/356), Defendant was again evasive and refused to answer questions during her second deposition, despite the court’s specific direction that she sit for her deposition and answer topic areas that she avoided during her first deposition. See id. Ms. Giuffre ' Maxwell Depo. Tr. at 287:24-25.