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Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 20 of 45 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) Ms. Giuffre additionally objects to this request in that it is sought solely to harass, and intimidate Ms. Giuffre who is a victim of sexual abuse by the Defendant. Ms. Giuffre objects on the basis that Defendant is not entitled to a full-scale production of everything that has happened throughout the entire course of her life time, particularly the time sought in this request which predates Defendant’s meeting and abuse of Ms. Giuffre. A victim of sexual abuse should not be re-abused by having to disclose events that occurred prior to the time that she was sexually abused by Maxwell and her co-conspirators. Furthermore, discovery concerning Ms. Giuffre’s prior sexual assault is not relevant to the claim at issue in this case, the defenses at issue, or the damages claimed, and therefore well outside the scope of discovery permitted by Fed. R. Civ. P. 26. Specifically, Ms. Giuffre’s sexual abuse as minor child neither proves nor disproves Defendant and Epstein’s sexual abuse; therefore, it is not within the scope of discovery permitted by Fed. R. Civ. P. 26, particularly since the December 1, 2015, amendments to the Rule. “Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.” Fed. R. Civ. P. 26(b)(1). Giving testimony on such irrelevant, but painful, topics would be extraordinarily embarrassing, oppressive, and traumatic for Ms. Giuffre, and it is wholly irrelevant to any party’s claim or defense. Accordingly, such discovery is not sought in good faith. This request is particularly improper as it cannot conceivably lead to admissible evidence. While Federal Rule of Civil Procedure 26 controls the limits of discovery, FRE 412 19