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Case 1:15-cv-07433-LAP Document 1320-28 Filed 01/03/24 Page 9 of 32 June 18, 2016). “Good cause” and diligence were not shown when a party raised the prospect of a deposition nine days prior to the discovery deadline. Carlson v. Geneva City School Dist., 277 F.R.D. 90 (W.D.N.Y. 2011); compare Reese v. Virginia Intern. Terminals, Inc., 286 F.R.D. 282 (E.D. Va. 2012) (depositions noticed very early in discovery period and movant engaged in continuing meet-and-confer dialogue with defendants throughout five month discovery period); Iantosca v. Benistar Admin. Svcs., Inc., 765 F.Supp.2d 79 (D. Mass. 2011) (correspondence indicated that the plaintiffs had tried on numerous occasions to schedule the depositions and to extend the discovery schedule but that the defendants had either refused or failed to respond, good cause found). ARGUMENT L PLAINTIFF’S LACK OF DILIGENCE Plaintiff has demonstrated an extreme lack of diligence in securing the remaining six depositions that she seeks. A. President Bill Clinton Plaintiff's Motion failed to mention any desire to take the deposition of former President Clinton. No Notice of Deposition has been served and no scheduling of his deposition has commenced. Indeed, President Clinton first appeared on Plaintiff's Third Revised Rule 26 Disclosures two weeks ago on June 1. Then, last week, in her Reply In Support of Motion to Exceed Ten Depositions filed on June 13 (“Reply”), Plaintiff averred that President Clinton’s deposition is “necessary” because Ms. Maxwell “in her deposition [on April 25] raised Ms. Giuffre’s comments about President Clinton as one of the ‘obvious lies’ to which she was referring in her public statement that formed the basis of this suit.” Reply at 3. This is utter nonsense and nothing more than a transparent ploy by Plaintiff to increase media exposure for her sensational stories through deposition side-show. This witness has nothing relevant to add 6