Case 1:15-cv-07433-LAP Document 1198-19 Filed 01/27/21 Page 1 of 9 United States District Court Southern District of New York Plaintiff. Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell. Defendant. PLAINTIFF SUR-REPLY IN RESPONSE TO DEFENDANT'S REPLY IN SUPPORT OF MOTION FOR SANCTIONS Plaintiff, hereby submits this stir-reply in response to Defendant's Reply in Support of Motion for Sanctions, responding to Defendant's new — and inaccurate — representation of facts. I. CORRECTIONS TO DEFENDANT'S FACTUAL MISREPRESENTATIONS does not make new arguments in this brief, but, instead, rebuts some of the most significant factual inaccuracies throughout Defendant's reply brief. A. has Properly Disclosed Dr. Del Mar. Defendant claims in her reply that the "Donahue records reveal a completely new doctor," Dr. Del Mar, that failed to disclose. This is a misrepresentation for two reasons. First, Dr. Del Mar and his records have obviously been disclosed, as Defendant's reply brief makes clear. Second, Dr. Donahue has a practice with at least one other physician, including Dr. Del Mar. 1 EFTA02784657