Document 1295-7 Case 1:15-cv-07433-LAP BOI ES, SCH I LLER 8 Filed 12/12/22 FLEXNER Page 1 of 4 LLP 401 EAS - LAS OLAS SOJLEVARD • SUITE 1200• FORT LAUDERDALE. FL 33301 2211 • Pr 954 356 00 ! • FAX 954 356.0022 FILED UNDER SEAL Sigrid McCawlcy, Esq. E-mail: smccawlevObsilb.com January 19, 2017 VIA EMAIL Honorable Judge Robert W. Sweet District Court Judge United States District Court 500 Pearl Street New York, NY 10007 Re: v. Maxwell, Case No.: IS-cv-07433-RWS Dear Judge Sweet, This is a letter motion to reopen discovery to allow inclusion of a newly-discovered witness, to be called to testify in Plaintiff's case-in-chief at trial. is an individual who appears on Jeffrey Epstein's private jet flight l2gL which have been produced in this case. Plaintiff's counsel heretofore had no way to locate nor any way to ascertain whether she had information relevant to this case. Recently, on her own initiative, contacted Professor Paul Cassell, counsel of record in this case, and someone with a reputation for being an advocate for crime victims. In her telephone call to Professor Cassell, she identified herself as someone with important information about the claims at issue in this case. Specifically, can testify about Defendant's involvement in Jeffrey Epstein's sex trafficking ring. Her testimony will directly refute sworn testimony given by Defendant. Once submitted a revised Rule 26 Disclosure to the Defendant specifically naming this new witness and sent a letter to Ms. Maxwell's counsel offering to coordinate to make this witness available for deposition if Ms. Maxwell desired to take her deposition. As Plaintiff has described, Defendant and Jeffrey Epstein worked in concert to recruit and sexually exploit young girls. They also went to extensive lengths to keep their activities a secret. In addition to Defendant and Epstein, the other primary witnesses to this WW1N BSFLLP.COM EFTA02789450