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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 29 of 50 outside the scope of discovery permitted by Fed. R. Civ. P. 26. Specifically, Ms. Giuffre’s sexual abuse as minor child neither proves nor disproves Defendant and Epstein’s sexual abuse; therefore, it is not within the scope of discovery permitted by Fed. R. Civ. P. 26, particularly since the December 1, 2015, amendments to the Rule. “Parties may obtain discovery regarding any non-privileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.” Fed. R. Civ. P. 26(b)(1). Engaging in discovery on such irrelevant, but painful, topics would be extraordinarily embarrassing, oppressive, and traumatic for Ms. Giuffre, and it is wholly irrelevant to any party’s claim or defense. Accordingly, such discovery is not sought in good faith. Additionally, to the extent that it is available to Ms. Giuffre, all of this information is already in the possession of Maxwell as she obtained and produced police reports regarding Ms. Giuffre, which Ms. Giuffre did not have in her possession. Ms. Giuffre was also questioned for seven hours in her May 3, 2016, deposition by Defendant’s attorney. 4. Sexual Assault Records are Records a Medical Event, and Are Barred by This Court’s Order - Discovery Related to Interrogatory No. 14 is Inappropriate Moreover, this Court has excluded the production of medical records from prior to 1999, stating, “the damage issue relates, in my view, solely to the defamation.” (April 21, 2016, Hearing Transcript at 20:23-24). This holding applies equally to pre-1999 sexual assault records for two reasons. First, sexual assault is not only a crime, but a physical injury, and an injury for which medical treatment is often needed and for which a forensic medical exam is often 23