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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 15 of 50 any statements made about her, throughout the internet and other sources, and determine whether or not they constitute defamation. Accordingly, this request is overly broad. See December 29, 2005 Discovery Order, American Civil Liberties Union, et. al. v. Alberto R. Gonzales, No. 98-- 5591, at p. 6 (E.D. Pa. Dec. 29, 2005) (“I find that interrogatory P is over-broad because it is not limited to speech defendant has already determined to be ‘harmful to minors’ under COPA but appears to command defendant to search for all speech over the entire internet and determine whether it is harmful to minors. As a result, defendant need not response to plaintiffs’ interrogatory P.”), at McCawley Decl. at Exhibit 2, for ease of reference. Alan Dershowitz is the only other known person to defame Ms. Giuffre. As with Interrogatory No. 5, there is no way for Ms. Giuffre to know the full extent of Alan Dershowitz’s defamation of her. She knows that he has called her a “prostitute” and a “bad mother” during his press conferences. See McCawley Decl. at Exhibit 3, Local 10 News article dated January 22, 2015. But, Ms. Giuffre does not know the full extent of Alan Dershowitz’s defamation, nor has she conducted legal analysis regarding any such defamation. Any party could attempt a Google search of such things to locate certain sources on the internet, but that is not what is contemplated by Rule 26(b)(1), Federal Rules of Civil Procedure, as such an exercise is unduly burdensome, and such information is well outside of Ms. Giuffre’s possession, custody, and control. Moreover, only Alan Dershowitz (Defendant’s joint defense partner) knows the comprehensive list of his defamatory statements and of the outlets to which he distributed them. Rule 26(b)(1) limits the scope of discovery based on an evaluation of “the parties’ relative access to relevant information.” As Dershowitz himself has admitted, he is actively involved with Defendant in this litigation. Defendant’s access to this information relative to Ms. Giuffre’s is unparalleled. It is unduly burdensome for Ms. Giuffre to troll the