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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 10 of 50 Weissfeld. The overwhelming majority of them were produced in her second rolling production and continued on a rolling basis through the fifth production (all of which were small productions). Specifically, there are approximately 175 of these documents, and all were produced within a narrow Bates range.* Defendant had knowledge of these documents as soon as Ms. Giuffre produced them. Moreover, these documents are featured in Defendant’s briefs, Defendant issued subpoenas to both Sharon Churcher and Jarred Weissfeld months ago, and Defendant has deposed Ms. Giuffre about her media contacts. See McCawley Decl. at Composite Exhibit 1, Defendant’s May 31, 2016, Subpoenas to Churcher and Weissfeld. Yet, Defendant cited a number of cases wherein discovery was buried amid voluminous productions so as to be hidden or to cause delayed or cumbersome discovery of them. They are inapposite. Defendant didn’t have to “comb through literally thousands of pages of documents” to “find” these. Again, they were presented to Defendant in small production batches, starting with the second production. Moreover, Defendant can gather all of these documents via an electronic search with a simple keystroke. By suggesting to the Court that Ms. Giuffre’s communications with the media were somehow hidden or buried in her production, Defendant makes an argument in bad faith. Indeed, Defendant’s argument is tantamount to making a false representation to the Court. Finally, all of these communications were email communications. So, on their face, they 99 66, tell Defendant “the date of any such Communication;” “the form of any such Communication, whether oral or written and if written, the format of any such Communication;” “the identities of all the persons involved in such Communication” (this is revealed from the to/from/cc lines); and the other data. Defendant also knows, very well, the identities of the individuals involved > These communications were produced at Giuffre003 191-4274; Giuffre004275-4301; Giuffre004302-4371; Giuffre004372-4746; Giuffre004747-5092. 4