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Case 1:15-cv-07433-LAP Document 1331-12 Filed 01/05/24 Page 4 of 10 BOIES, SCHILLER & FLEXNER LLP Honorable Judge Robert Sweet United States District Court Page -4- Confidential Sealed Filing Defendant’s argument about her alleged burden from allowing this one additional witness also rings hollow.’ Defendant complains about her alleged lack of resources, but as this Court is aware, Defendant is a wealthy socialite (who recently sold her New York Townhome for $15 million dollars) who has heavily litigated this case in ways that were completely unnecessary. * Moreover, deposition discovery is still ongoing in this case. Ms. Kellen sat for her deposition last week (wherein she invoked the Fifth Amendment when asked about Defendant’s involvement in Epstein’s sex trafficking ring) along with Ms. Marcinkova who was recently deposed on January 17, 2017. Due to Defendant's unwillingness to produce her agent, Ross Gow for deposition, Ms. Giuffre did not get to depose him until November 18, 2017 at which time he produced never-before-seen documents that are critical to this case. Defendant has yet to sit for her follow-up deposition that was directed by the Court but for which Defendant filed a “Motion for Reconsideration” on November 16, 2016, which is still pending. Needless to say, while the official discovery deadline has closed, certain depositions have been taken more recently due to issues with witness cooperation. Of course, if Defendant does not desire to take Ms. Ransome’s deposition, then Ms, Giuffre is content simply calling her at trial. But Defendant will hardly be prejudiced by allowing a witness to testify who is available for deposition. Defendant argues that because Jane Doe 43 (who for purposes of this sealed filing we can identify as Ms. Ransome) has recently filed a complaint against multiple defendants for violations of sex trafficking laws that Defendant should get to reopen discovery and further investigate everyone named as a Defendant. Notably, these are all individuals that were part of the sexual trafficking ring that Defendant was a party to and she has known about them and interacted with them for years. Ms. Ransome’s claim had to be filed swiftly because her statute of limitations was continuing to run and the details of her allegations only recently became known to counsel. In any event, the questions that need to be asked of Ms. Ransome are simply and straightforward: Was Defendant involved in Epstein’s sex trafficking ring? That question has been at the heart of this case for many months and exploring it does not raise any new issues. *For example, Defendant litigated over the production of facially non-privileged documents; Defendant filed no fewer than three frivolous sanctions motions; Defendant filed Daubert challenges to all six of Ms, Giuffre’s expert witnesses; and Defendant has filed discovery motions without even conferring with Ms. Giuffre in advance, including one for which Ms. Giuffre did not oppose the relief sought (Defendant’s motion to reopen Ms. Giuflre’s deposition), Further, Defendant apparently had the resources to file approximately 100 pages of single-spaced objections to Ms. Giuffre deposition designations, an unorthodox volume that stands out not simply because this is a one-count defamation claim, but because she objects to the same type of testimony that she has designated for admission.