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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 16 of 50 internet for any instances of Dershowitz defaming her. He is not a party to this action. And, Ms. Giuffre’s single count of defamation does not allege in facts in relation to Dershowitz. Accordingly, the Court should deny Defendant’s motion. D. Interrogatory No. 8 Defendant seeks a list of all the individuals to whom Epstein trafficked Ms. Giuffre. Under Local Rule 33.3 interrogatories “may only be served (1) if they are a more practical method of obtaining the information sought than a request for production or a deposition, or (2) if ordered by the Court.” Defendant has already lit upon “a more practical method of obtaining the information sought.” She asked Ms. Giuffre for this information in her deposition. Moreover, Dershowitz, Defendant’s joint defense partner, asked for this information when he took her deposition, and Ms. Giuffre produced that deposition transcript to Defendant. This request is redundant, as this information has already been sought and Ms. Giuffre responded to questions at her May 3, 2016, deposition. See, e.g., May 3, 2016, Giuffre Dep. Tr. at 192-193, 200; 14; 191-193; 193-194; 201-202; 2020-203; 204; January 16, 2016, Giuffre Dep. Tr. at 15; 34; 50-51; 24; 41; 45; 51-54; 6; 38; 24-25; 18-19; 21; 61; 17-18; 20-21; 33; 18; 15-16; and 21. E. Interrogatory No. 13 1. Ms. Giuffre Has Answered Interrogatory No. 13 Completely As discussed above, Defendant’s entire motion violates Local Rule 37.1, but she does so most egregiously here. This interrogatory seeks Ms. Giuffre’s health care provider for any physical, mental, or emotional condition, prior to the Defendant’s defamation. Defendant does not include Ms. Giuffre’s hard-won and fulsome answer, which includes a bevy of providers going back many years. The reason for Defendant’s Rule violation with regard to this 10