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Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 14 of 17 The questions Defendant refused to answer fall squarely within this Court’s earlier order. Defendant can have no legitimate basis for obstructing the search for truth by refusing to answer. The Court should, again, compel Defendant to answer all these questions. See Fed. R. Crim. P. 37(a)(3)(B)(); see, e.g., Kelly v. Al Tech., No. 09 CIV. 962 LAK MHD, 2010 WL 1541585, at *20 (S.D.N.Y. Apr. 12, 2010) (“Under the Federal Rules, when a party refuses to answer a question during a deposition, the questioning party may subsequently move to compel disclosure of the testimony that it sought. The court must determine the propriety of the deponent's objection to answering the questions, and can order the deponent to provide improperly withheld answers during a continued deposition” (internal citations omitted)). Of course, the party objecting to discovery must carry the burden of proving the validity of its objections, particularly in light of “the broad and liberal construction afforded the federal discovery rules... .” John Wiley & Sons, Inc. v. Book Dog Books, LLC, 298 F.R.D. 184, 186 (S.D.N.Y. 2014). For purposes of a deposition, the information sought “need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence.” Chen- Oster v. Goldman, Sachs & Co., 293 F.R.D. 557, 561 (S.D.N.Y. 2013) (citing Fed.R.Civ.P. 26(b)(1)). Defendant cannot claim that such questions were outside the scope of this Court’s order, as they directly relate to (1) her knowledge of individuals who provided “massage” to Epstein and (2) her knowledge of sexual activities of others with or involving Epstein. Defendant’s knowledge of the individuals involved in the sex/’massages” relating to Epstein, and her knowledge about the sex/’massage” related to Epstein is precisely what this Court directed her to answer. See also, Condit v. Dunne, 225 F.R.D. 100, 113 (S.D.N.Y. 2004) (in defamation case, “Plaintiff is hereby ordered to answer questions regarding his sexual relationships in so far as 14