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Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 10 of 40 Plaintiffs deficient answer. “Notwithstanding” her objections, Plaintiff “answered” by referring the defense to 7,566 pages of documents (“Ms. Giuffre has already produced her responsive communications, which are found in documents Bates labelled GIUFFRE000001 to GIUFFRE007566.”). The vast majority of these documents do not contain any communications between Plaintiff and her lawyers, on the one hand, and media representatives, on the other. The answer is improper. See, e.g., In re Ethicon, Inc., Pelvic Repair Sys. Prod. Liab. Litig., No. MDL 2327, 2013 WL 8744561, at *3 (S.D.W. Va. July 26, 2013) (finding interrogatory responses insufficient where they instructed plaintiffs to search mass of documents for requested information); Nickerman v. Remco Hydraulics, Inc., No. C 06-2555SI, 2007 WL 3407437, at *3 (N.D. Cal. Nov. 13, 2007) (“Despite repeated admonitions against doing so, plaintiffs continue to provide general and vague responses and to direct defendants to masses of documents.... Neither defendants nor the Court should be expected to comb through literally thousands of pages of documents searching for documents that might support plaintiffs’ IED claims.”). Interrogatory No. 6. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as You contend in paragraph 9 of Count 1 of Your Complaint, including: a. the exact false statement; b. the date of its publication; c. the publishing entity and title of any publication containing the purportedly false statement; d. the URL or internet address for any internet version of such publication; and e. the nature of the publication, whether in print, internet, broadcast or some other form of media. Response: Ms. Giuffre objects because the information interrogatory above is in the possession of Defendant who has failed to comply with her production obligations 7