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Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 15 of 17 they are relevant to a defense of substantial truth, mitigation of damages, or impeachment of plaintiff.”); Weber v. Multimedia Entm't, Inc., No. 97 CIV. 0682 PKL THK, 1997 WL 729039, at *3 (S.D.N.Y. Nov. 24, 1997) (“While discovery is not unlimited and may not unnecessarily intrude into private matters, in the instant case inquiry into private matters is clearly relevant to the subject matter of the suit. Accordingly, plaintiff Misty Weber shall respond to defendants' interrogatories concerning her sexual partners . . . .”). Moreover, generally speaking, instructions from attorneys to their clients not to answer questions at a deposition should be “limited to [issues regarding] privilege.” Morales v. Zondo, Inc., 204 F.R.D. 50, 54 (S.D.N.Y. 2001). In this case, defense counsel once again ranged far beyond the normal parameters of objections and gave instructions directly in contravention of this Court’s Order directing Defendant to answer exactly the type of questions posed to her. In light of Defendant’s willful refusal to comply with this Court’s Order directing Defendant to answer questions related to the Court’s June 20, 2016, Order, including topics enumerated above, Ms. Giuffre also seeks attorneys’ fees and costs associated with bringing this motion, as well as fees and costs associated with re-taking Defendant’s deposition. CONCLUSION Defendant should be ordered to sit for a follow-up deposition and directed to answer questions regarding the topics enumerated above. Dated: July 29, 2016 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) 15