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Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 21 of 27 the discovery context is broader than in the context of admissibility should not be misapplied so as to allow fishing expeditions in discovery." /d. (quotation omitted). Under Rule 26(c) of the Federal Rules of Civil Procedure any party may move the court, for good cause shown, for a protective order regarding pretrial discovery “which justice requires to protect a party or person from annoyance, embarrassment, oppression or undue burden or expense.” Fed. R. Civ. P. 26(c). “Although the Rule contains no specific reference to privacy or to other rights or interests that may be implicated, such matters are implicit in the broad purpose and language of the Rule.” Seattle Times Company v. Rhinehart, 467 U.S. 20, 35 (1984). It is important to consider, again, that Ms. Maxwell is the defendant in this action. She has not put her private affairs at issue. She simply denied that she assisted Jeffrey Epstein in the sexual trafficking of the Plaintiff. It is also important to recognize that Ms. Maxwell is not Mr. Epstein and Mr. Epstein’s alleged conduct after Plaintiff left the country is not an issue in this defamation case. The Plaintiff has no personal knowledge of any of Mr. Epstein’s activities after 2002. Accordingly, any statements by Plaintiff about Mr. Epstein’s activities occurring after 2002 are her opinions, not facts that are subject to any defamation claim. I. THE PURPORTED “FACTUAL BACKGROUND” CITED BY PLAINTIFF IS NOT RELEVANT TO THE ISSUES IN THE CASE OR THIS MOTION As Carl Sandburg famously said, “If the facts are against you, argue the law. If the law is against you, argue the facts. If the law and the facts are against you, pound the table and yell like hell.” In this case, rather than pound the table, Plaintiff tries to distract from the issues at hand — whether Ms. Maxwell fully answered all questions posed — by pointing to selective misleading quotes from various other witnesses who have been deposed in this case. When viewed in their entirety, those witnesses neither support Plaintiff's single claim for defamation nor her claim for