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Case 1:15-cv-07433-LAP Document 1325-14 Filed 01/04/24 Page 20 of 30 Ms. Giuffre has had to litigate, multiple times, for Defendant to make any document production, and Ms. Giuffre has had to litigate, also multiple times, for Defendant to be deposed. See Plaintiff’s Response in Opposition to Defendant’s Motion to Stay Discovery (DE 20); Plaintiff's February 26, 2016, Letter Motion to Compel Defendant to Sit for Her Deposition; Plaintiff's Motion to Compel Documents Subject to Improper Claim of Privilege (DE 33); Plaintiffs Motion to Compel Documents Subject to Improper Objections (DE 35); Plaintiffs Response in Opposition to Defendant’s Motion for a Protective Order Regarding Defendant’s Deposition (DE 70); Plaintiffs Motion for Forensic Examination (DE 96); Plaintiff's Motion to Compel Defendant to Answer Deposition Questions (DE 143). Ms. Giuffre has had to expend considerable time and resources simply to have Defendant meet her basic discovery obligations in this case. Now, having completely stonewalled on discovery, making every produced document and even her own deposition the result of extensive and unnecessary litigation, taking positions that are contrary to the Federal Rules and wholly contrary to prevailing case law, Defendant claims that Ms. Giuffre has been “non-compliant since the outset of discovery.” (Mtn. at 11). This statement is completely inaccurate. Defendant makes a number of unsubstantiated claims regarding law enforcement materials, photographs, and email accounts. Most of these issues have been resolved pursuant to this Court’s orders. See June 20, 2016, Order entered under seal denying Defendant’s motion to compel law enforcement materials; June 23, 2016, Minute Entry. Ms. Giuffre merely points out that Defendant not only failed to review, search, or produce Defendant’s email, from any of her multiple accounts, but also wholly failed to disclose her terramarproject.org email account or her ellmax.com email account. 16