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19. Wil 7) Us} 14 AN} 16 I ke alts) 20 all 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-2 Filed 01/08/24 Page 33 of 42 ey XGAQGIUc SEALED the deposition both to ask questions about the lately produced evidence, as well as the ones she refused to answer in violation of the order. MR PAGLIUCA: Your Honor, let me start with the reference to plaintiff's conduct during her deposition, which is wholly different than the issue before the Court now. At the direction of her lawyers, Ms. Giuffre refused to answer multiple relevant questions throughout the course of the deposition. The conduct in that deposition after we filed a motion to compel, her lawyers agreed that she needed to sit for a second deposition, and the only issue was whether it was going to be done by video conference or in person. Because of the egregious nature of the conduct, they knew that they had no chance at defeating that motion to compel. Here, your Honor, we are talking about two emails that were inadvertently not included in the production. We thought they had been produced, and when we went back through the documents, it appeared that they hadn't, so we produced them, as is our obligation under Rule 26. The first email, your Honor, is an email from Mr. Gow to Mr. Barden and Ms. Maxwell that is forwarding an email from The New York Times and simply it says, you know, please advise how you wish to respond. That's it. That's the entirety of this email. There is no response from Ms. Maxwell. So what we're talking about here is an email that Mr. Gow forwarded SCUTHERN DISTRICT REPORTERS, (Pic, (212) 805-0300