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10 AL Al, AL} is} 14 15} AN) a +e AES) 20 PAL 22 7-43} 24 25 Case 1:15-cv-07433-LAP Document 1332-2 Filed 01/08/24 Page 31 of 42 30 XGAQGIUc SEALED Here, defendant failed to produce two important documents until after her deposition and after the close of discovery. These documents are communications with Jeffrey Epstein, her co-conspirator and convicted pedophile, as well as with Ross Gow, her press agent who assisted her in issuing the defamation statement that is at issue in this case. As this Court will recall, defendant and her attorney, Phil Barden, wrongfully refused to produce her agent Ross Gow and forced Ms. Giuffre to spend tens of thousands of dollars to secure his deposition, finally taking place next week. If Ms. Giuffre is not afforded the opportunity to ask defendant question about these documents, she will be prejudiced and defendant will be rewarded for her failure to make a timely production. Not only are these documents communications with key witnesses, your Honor, they're about a central topic to this case, defaming Ms. Giuffre through the media. These are not emails about the weather or anything like that. They're discussing further public statements about Ms. Giuffre. And importantly, your Honor, these communications took place after the original defamatory statement and one after the commencement of this litigation. Defendant has argued that because Ms. Giuffre asked her questions about other communications she's had with these two individuals, it's unnecessary to ask about these documents. That argument is just unsupported by the facts, and defendant SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300