Giuffre_Maxwell_Batch4_p00314.png

Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 11 of 50 (including the identity of the organization with which they are affiliated), particularly as the communicators each received one of Defendant’s subpoenas. At the end of the day, the only thing Ms. Giuffre could do to answer this any more than she already has is to go through the burdensome and redundant exercise of writing down, for each of the approximately 175 emails, (1) the fact that it is an email; (2) what name appears in the “to” field; (3) what name appears in the “from” field; (4) what name appears in the “cc” field; and (5) what date appears on the email. Ms. Giuffre submits to the Court that making such a catalogue is a redundant exercise that is not appropriate under Rule 26(b)(1) which, under the 2015 amendment, takes into account “‘the parties’ relative access to relevant information.” Ms. Giuffre also submits to the Court that moving to compel Ms. Giuffre to make such a list based on documents she already produced to the Defendant is frivolous and a waste of resources. B. Interrogatory No. 6 Defendant’s Interrogatory No. 6 seeks any “false statements” attributed to Defendant that were published. Defendant also seeks the date, place, and form of publication, publishing entity, the URL address, etc., of all such statements. Ms. Giuffre knows, with certainty, of certain statements made by Defendant, and, together, they are the subject of this action. Ms. Giuffre made a listing of various websites that published those statements in response to this interrogatory. This compilation was part of Ms. Giuffre’s interrogatory answer that Defendant misleadingly omits from her motion in violation of Local Rule 37.1. Based upon Ms. Giuffre’s answer, there is nothing else to compel. Yet, Defendant moves to compel answers that Ms. Giuffre does not have. Specifically, Ms. Giuffre does not have the knowledge (and certainly does not have the documents relating to) every time Defendant may have defamed her. That is information that lies solely in the possession of the Defendant. Indeed, Ms. Giuffre sought this very information from 5