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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 39 of 50 h. For each such Health Care Provider, please execute the medical and mental health records release attached hereto as Exhibit A. 14. Identify any Person who You believe subjected You to, or with whom You engaged in, any illegal or inappropriate sexual contact, conduct or assault prior to June 1999, including the names of the individuals involved, the dates of any such illegal or inappropriate sexual contact, conduct or assault, whether Income was received by You or anyone else concerning such event, whether a police report was ever filed concerning such event and the outcome of any such case, as well as the address and location of any such event. Regarding documents related to Interrogatory No. 5, as described above, Ms. Giuffre has already produced her communications with the media, and a request for communications among her counsel and the media is overly-broad to the point of total impracticality and absurdity. Therefore, this request should be denied. Regarding documents related to Interrogatory No, 6, Ms. Giuffre has already produced documents (or world-wide-web links to documents) in which Defendant has defamed her. Any more exhaustive search of the internet for additional documents, is not something contemplated by the Local Rules. Additionally, Ms. Giuffre has no documents related to any other defamation of Ms. Giuffre Defendant may have caused. Therefore, there is nothing further to “compel,” and this request should be denied. Defendant should be producing this responsive material, not Ms. Giuffre. Regarding documents related to Interrogatory No. 7, Ms. Giuffre does not have documents relating to other’s defamation of her. She knows of a few statements made by Alan Dershowitz, but causing Ms. Giuffre to go through a time-consuming, burdensome, and, frankly, emotionally upsetting, exercise of searching around for whatever else he may have said is outside the scope of Rule 26, as discussed above, particularly as Ms. Giuffre has not based any part of her claim off of those statements. Accordingly, this request should be denied. 33