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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 7 of 50 Plaintiff Virginia Giuffre (“Ms. Giuffre”), by and through her undersigned counsel, hereby files this Response in Opposition to Defendant’s Motion to Compel and her baseless Motion for Sanctions (DE 354). L INTRODUCTION For the third time, Defendant attempts to elevate a routine discover dispute into something over which she seeks sanctions, despite the complete lack of a basis for sanctions and a complete lack of case law supporting her request.’ All three of Defendant’s requests for sanctions have been frivolous, legally unreasonable, without factual foundation, and for an improper purpose. Rule 11 provides for the imposition of sanctions in those circumstances. See Elghanian v. Schachter, 1997 WL 607546, at *2 (S.D.N.Y. 1997) (Sweet, J.) Indeed, in Defendant’s entire “argument” for sanctions, she only cites one case - a case from the District of the District of Columbia - for the proposition that Plaintiff should be sanctioned because her interrogatory responses were unsigned.” However, Defendant’s interrogatory responses are also unsigned. Defendant’s thirty-seven page brief is riddled with these half-truths in a grasping attempt to distort reality as the documentary and testimonial evidence piles up against her. By Defendant’s logic, Ms. Giuffre should have already moved for sanctions against Defendant for Defendant’s unsigned interrogatories, but unlike Defendant, Ms. Giuffre would not burden the Court with a frivolous request for sanctions. Il. DEFENDANT’S ENTIRE MOTION SHOULD BE DENIED Defendant’s motion violates Local Rule 37.1, and should be denied for that reason before the Court even reaches the merits. Local Rule 37.1 states that, “upon any motion or application ' Defendant’s first baseless request for sanctions was improperly raised in a response brief (DE 228) to a routine motion for extension of time - a motion this Court granted (June 23, 2016, Minute Order). Defendant’s second baseless request (DE 231) centered on the fact that Ms. Giuffre listed her physicians in response to interrogatories instead of in her Rule 26 disclosures. > Ms. Giuffre has signed her amended interrogatories, and has served them on Defendant. 1