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Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 15 of 40 Ms. Giuffre objects to this interrogatory in that it violates Rule 33 as its subparts, in combination with the other interrogatories, exceed the allowable twenty-five interrogatories. Ms. Giuffre also objects in that it seeks information protected by the attorney-client/work product privilege, and any other applicable privilege stated in the General Objections. Ms. Giuffre refers to the list of witnesses identified in her Revised Rule 26 Disclosures. Also, notwithstanding previously-noted objections, Ms. Giuffre testified in Edwards v. Cassell, Broward County Case Number CACE 15-000072 on January 16, 2016, regarding the subject matter requested. See GIUFFRE005094- GIUFFRE007566. Ms. Giuffre additionally testified regarding the subject matter requested in this interrogatory on in the above-captioned case in her deposition on May 3, 2016. Additionally, Ms. Giuffre was trafficked to other individuals whose name she never learned or whose names she does not remember. Identification of any other individuals would be irrelevant and unduly burdensome. Moreover, as specifically provided in Rule 33.3(b), “[dJuring discovery, interrogatories other than those seeking information described in paragraph (a) [] may only be served (1) if they are a more practical method of obtaining the information sought than a request for production or a deposition or (2) if ordered by the Court.” Because Ms. Giuffre has provided an answer to this interrogatory in her deposition, which was a more practical method of obtaining the information sought, this interrogatory is improper under the Local Rules as well as wholly duplicative. Subpart objection. This is addressed above in the discussion of Objection 1. Privilege assertion. This is addressed above in the discussion of Objection 6. It is inconceivable that any privilege applies to the identities of individuals to whom Plaintiff alleges she was sexually trafficked. This is a frivolous assertion of privilege. Plaintiffs deficient answer. Instead of identifying individuals as required by the interrogatory, Plaintiff instead “refer[red]” to her Rule 26 disclosures, her testimony in a Florida state case, and her earlier deposition in this case. This is non-responsive and evasive, in violation of Rule 37(a)(3). See, e.g., Public Storage v. Sprint Corp., No. CV 14-2594-GW PLAX, 2015 WL 1057923, at *17 (C.D. Cal. Mar. 9, 2015) (“Plaintiffs may not answer the interrogatory by generally referring Defendant to the pleadings filed in this case, documents produced, opt-in questionnaires, depositions, or declarations.... [A] responding party may not answer an interrogatory by directing the party propounding the interrogatory to find answers from 12