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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 14 of 50 January 5, 2015 | Internet/ | AOL UK http:/www.aol.co.uk/video/ghislaine-maxwell- Broadcast declines-to-comment-on-prince-andrew-allegations- 518587500/ Ms. Giuffre recently updated this response to include an additional URL containing defamatory content: January 8,2015 | Internet The Sun https://www.thesun.co.uk/archives/news/6754/princ e-andrews-pal-ghislaine-groped-teen- girls/?CMP=spklr-128508300-Editorial-T WITTER- TheSunNewspaper-20150108-News Spending hours trolling the Internet for additional examples of entities that have published Defendant’s defamatory statements is not appropriate under Rule 26(b)(1), which takes into account “whether the burden or expense of the proposed discovery outweighs the likely benefit.” Here, scouring the Internet for additional examples of the publication of the defamatory statements that are already known (and, illogically, for those that are unknown) is not an appropriate discovery request. If Defendant would respond to Ms. Giuffre’s requests, Ms. Giuffre would be able to answer this interrogatory in full. Only Defendant has access to a comprehensive list of her defamatory statements and of the outlets to which she distributed them. Indeed, as the Court knows from the documents it reviewed in camera and found were not privileged, Defendant and Dershowitz were regularly communicating regarding how best to attack Ms. Giuffre. Accordingly, the Court should deny Defendant’s motion Cc. Interrogatory No. 7 This interrogatory seeks a catalogue of all of defamatory statements made against Ms. Giuffre. This Interrogatory calls for a legal conclusion as to what statements constitute “defamation,” and is, thus, improper, particularly as it is not limited to what has already been determined to be defamatory. Specifically, this interrogatory calls for Ms. Giuffre to search for