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Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 8 of 10 one. Ms. Giuffre has described the frequency of these “massages”, the sexual tendencies of the participants, the manner in which the massages became sexual in nature, and Defendant’s role at each stage. In response, Defendant has called Ms. Giuffre’s entire account “untrue” and “obvious lies.” Defendant has instead tried to portray her role as nothing more than an Epstein employee performing typical household management duties. Any personal knowledge Defendant has of Epstein’s sexual tendencies, habits, and use of massage for sex is entirely relevant to either corroborate Ms. Giuffre’s account. Likewise, Defendant’s participation in any sexual acts with Epstein, in his presence, on his properties, using his mode of converting massages into sex, or with females will directly corroborate Ms. Giuffre’s account. On the other hand, without access to the answers to these inquiries, Ms. Giuffre will be unable to expose the bias of Defendant, unable to thoroughly cross-examine Defendant’s position that she was just a lowly employee, and most importantly unable to demonstrate through the Defendant’s own admissions that Ms. Giuffre’s statements about Epstein and Defendant were absolutely true — and not “obvious lies.” Finally, Defendant fails to recognize that, for the discovery purposes at issue here, relevance “is an extremely broad concept.” Am. Fed'n of Musicians of the United States & Canada v. Sony Music Entm't, Inc., No. 15CV05249GBDBCM, 2016 WL 2609307, at *3 (S.D.N.Y. Apr. 29, 2016). And once relevance is shown, “the party resisting discovery bears the burden of demonstrating that, despite the broad and liberal construction afforded the federal discovery rules, the requests are irrelevant, or are overly broad, burdensome, or oppressive.” Id. Here, the requests are not “overly broad” as Ms. Giuffre’s specific explanations of the targets of her questions make clear. Moreover, answering the questions is not “oppressive,” particularly given the fact that Defendant has placed a// substantive aspects of the Deposition under seal. Of