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Case 1:15-cv-07433-LAP Document 1332-15 Filed 01/08/24 Page 4 of 11 Furthermore, Jane Doe 43 has good reason to believe that the Epstein Defendants also have the nefarious purpose of utilizing the confidential documents to humiliate and embarrass her in a public filing. This tactic should not be tolerated, and for that, their motion to modify should be denied. I. Jane Doe 43 and Virginia Giuffre Have Already Agreed to Disclose Any Remotely Relevant Testimony and Documents As an initial matter, Jane Doe 43 and Virginia Giuffre have already agreed to release Jane Doe 43’s deposition transcript and 56' documents that she produced from the confines of the Protective Order. Epstein Defendants spend a substantial amount of time in their Motion to Intervene trying to convince this Court that Jane Doe 43’s testimony, which they label the “Agreed Evidence,” establishes that she was not trafficked during the statute of limitations period. That could not be further from the truth. Jane Doe 43’s testimony clearly establishes that her abuse continued within the ten (10) year statute of limitations period: e She provided testimony demonstrating that Epstein’s abuse of Jane Doe 43 continued during the ten (10) year window before she filed her lawsuit against him. Jane Doe 43 Dep. Tr. 216; 250-251; Jane Doe 43000002-15. e She testified that she and the other girls were frightened of Epstein and Ghislaine Maxwell. Jane Doe 43 Dep. Tr. 44; 283. e She testified that she was held against her will on Epstein’s island. Jane Doe 43 Dep. Tr. 209. e She testified that Epstein and Maxwell, knowing Jane Doe 43 was financially destitute, and was suffering from depression, lured her into their commercial sex trafficking ring with the false promises of taking care of her and paying for her education if she complied with their demands. Jane Doe 43 Dep. Tr. 112; 233; 250-251. ' Jane Doe 43 inadvertently failed to include Document 000425-426 and hereby incorporates that email, which is from 2007, into the documents she has agreed to release. 4