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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 12 of 50 Defendant in her Requests Nos. 17 and 18, in which she requested documents “concerning any statement made by You or on Your behalf to the press or any other group or individual, including draft statements, concerning Ms. Giuffre, by You, Ross Gow, or any other individual, from 2005 to the present, including the dates of any publications, and if published online, the Uniform Resource Identifier (URL) address” and “all documents concerning which individuals or entities You or Your agents distributed or sent any statements concerning Ms. Giuffre referenced in Request No. 17 made by You or on Your behalf.” Defendant objected to these requests and refused to produce any documents. Ms. Giuffre’s motion to compel is pending. As stated above, Ms. Giuffre knows that Defendant defamed her through the statement issued on her behalf by Ross Gow, and she knows Defendant defamed her when she affirmed that statement on video the next day in New York. But, she doesn’t know all Defendant’s defamatory statements, nor does she know where Defendant made them, or to whom she issued them. Defendant is trying to turn logic on its head with this request which, essentially, says: “You tell me the people to whom I have sent my own defamatory statements.” Indeed, Defendant’s own language belies her argument. In the instant brief, Defendant says: “The interrogatory required Plaintiff, among other things, to provide each “exact false statement” that she attributes to Ms. Maxwell and that was published anywhere in the world.” How Ms. Giuffre can know every person to whom Defendant made defamatory statements is unexplained. For example, if Defendant took her defamatory statements to a media outlet that chose not to publish them, there is no way for Ms. Giuffre to know that. The only person who knows the full extent of Defendant’s defamation of Ms. Giuffre is defendant, which is why Ms. Giuffre sent her a request for the same information.