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Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 14 of 40 defamed by Alan Dershowitz, but she failed to provide any information about the allegedly defamatory statements made by Mr. Dershowitz. For example, she failed to disclose “[t]he exact false statement[s]” made by Mr. Dershowitz, the date of the publication, the publishing entity, and the other information required in the interrogatory. As justification for her failure to answer the interrogatory fully, Plaintiff argued she “does not have knowledge as to every time and place that she was defamed by Dershowitz.” That argument is meritless. This interrogatory required Plaintiff to disclose her knowledge as to each of the interrogatory’s subparts. She improperly failed to disclose this information. Plaintiff argued that “identification of the numerous publically [sic] made statements would be unduly burdensome.” She also argued that Mr. Dershowitz’s defamatory statements “are within the knowledge and possession of [Ms. Maxwell] and her attorneys or can be easily obtained by contacting [Mr. Dershowitz].” Neither was a responsive answer. To the extent they were offered as objections, they are meritless. See National Acad. of Recording Arts & Scis., 256 F.R.D. at 682 (cited in discussion of Objection 5). Interrogatory No. 8. Identify the individuals referenced in Your pleadings filed in the U.S. District Court for the Southern District of Florida, Jane Doe I and Jane Doe 2 v. United States of America, 08-cv-80736-KAM, as the “high-profile non-party individuals” to whom Mr. Jeffrey Epstein sexually trafficked You, “including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders,” including as to each episode of alleged sexual trafficking: a. the date of any such sexual trafficking; b. the location of any such sexual trafficking; c. any witnesses to any such sexual trafficking; d. any Income You received in exchange for such sexual trafficking; and e. any Documents You have to support or corroborate Your claim of such sexual trafficking. Response: 11