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Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 4 of 12 Defendant’s brief at p. 5, which is why Ms. Giuffre’s counsel had to respond to the media inquiry about it in the first place. A redacted name does nothing to protect Ms. Giuffre’s identity when Defendant is the one leaking the report to the press. Since Ms. Giuffre filed her motion for a Protective Order, Defendant’s joint defense partner, Alan Dershowitz, has also made distorted representations to the Court and asks, without standing, for this Court to strip away designations made under its order so that he, too, can take confidential litigation materials to the press.° As the adverse testimonial evidence piles up against Defendant,’ it appears she and Dershowitz are planning another media blitz in an attempt to discredit and defame Ms. Giuffre. The Court is aware that a mountain of testimonial evidence, from multiple witnesses, firmly establishes Defendant operated as convicted pedophile Jeffrey Epstein’s procurer of underage girls. The Court is also aware that, as things stand today, all of this testimony is under 3 Id. Ms. Giuffre will be filing an opposition to Dershowitz’s motion to intervene shortly. * See McCawley Decl. at Composite Exhibit 1, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103 (Figueroa testified that Plaintiff told him about threesomes with Defendant and Epstein which included the use of strap-ons); and Vol. 2 at 200 (Figueroa testified that Defendant called him inquiring if he had found any other girls for Epstein); Johanna Sjoberg’s May 18, 2016 Dep. Tr. at 8-9, 13, 33-35, 142-143(testifying that Defendant recruited her for sex with Epstein under the guise of answering phones, a job that lasted one day, because her second day Defendant asked her to start giving massages, and it soon made it clear that Sjoberg’s purpose was to bring Epstein to orgasm so Defendant didn’t have to all of the time); Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52-60 (Defendant’s friend’s house manager, through tears, described how Defendant tried to force a 15 year old Swedish girl to have sex with Epstein through threats and stealing her passport); Juan Alessi’s June 1, 2016 Dep. Tr. at 28, 52-54 (Epstein’s house manager, testified that Defendant was one of the people who procured the over 100 girls he witnessed visit Epstein, and that he had to clean Defendant’s sex toys); Lynn Miller’s May 24, 2016 Dep. Tr. at 115 (testified that Defendant became Ms. Giuffre’s “new momma”); Detective Joseph Recarey’s June 21, 2016 Dep. Tr. at 29-30 (the detective who led the investigation of Epstein, testified that Defendant procured underage girls for Epstein); David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34- 36; see also Exhibit 2 Excerpted Rodgers Dep. Ex. | at flight #s 1433-1434, 1444-1446, 1464- 1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589 (Epstein’s pilot testified that the passenger listed on his flight log bearing the initials - GM — was in fact Ghislaine Maxwell and Rodgers was the pilot on at least 23 of the flights in which Defendant flew with Plaintiff), etc.