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Case 1:15-cv-07433-LAP Document 1328-9 Filed 01/05/24 Page 15 of 21 on the basis of misrepresented or false facts or law) will be met with sanctions. VII. The Motion for Leave to Serve Three Deposition Subpoenas By Means Other than Personal Service is Granted in Part and Denied in Part Plaintiff seeks to compel subpoenas to serve Nadia Marcinkova, Sarah Kellen, and Jeffrey Epstein. The request is denied with respect to Epstein as moot. No opposition having been filed and the testimony of Marcinkova and Kellen being relevant to falsity of the defamation at issue, the motion is granted with respect to Marcinkova and Kellen. VIII. The Motion to Compel Attorney-Client Communications and Work Product is Denied Defendant argues that “Edwards and Cassell preemptively filed an action against Dershowitz proclaiming they did not violate Rule 11 .. . [and i]n doing so, they voluntarily put at issue and relied on: a) their good faith reliance on information communicated to them by Plaintiff, and b) their work product 14