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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 40 of 50 Regarding documents related to Interrogatory No. 8, seeking all documents relating to individuals to whom Ms. Giuffre was trafficked, Ms. Giuffre has already produced the documents in her possession. She has produced the photo of her when she was 17, taken inside Defendant’s apartment, with Prince Andrew’s hand around her bare waist while she was standing next to Defendant, and she has produced the deposition transcript wherein she testified about to whom she was trafficked, in Edwards v. Cassell, Broward County Case Number CACE 15- 000072 on January 16, 2016. See GIUFFRE005094- GIUFFRE007566. Ms. Giuffre additionally testified regarding the subject matter requested in this interrogatory on in the above-captioned case in her deposition on May 3, 2016, and that deposition transcript is also within Defendant’s possession. Because Ms. Giuffre has provided an answer to this interrogatory in her deposition, which was a more practical method of obtaining the information sought, this interrogatory is improper under the Local Rules as well as wholly duplicative. Regarding documents related to Interrogatory No. 9, which seeks Ms. Giuffre’s employment history, Ms. Giuffre has already answered that, and produced any corresponding documents she has and has obtained since the commencement of litigation. Ms. Giuffre dropped her claim for lost wages in her Amended Rule 26 disclosures rendering this interrogatory irrelevant which seeks over 20 years of employment information. Defendant puts forth no case law for the proposition that she is entitled to this discovery. Accordingly, Defendant’s request should be denied. Regarding documents related to Interrogatory No. 10 requests information concerning Ms. Giuffre’s income. Ms. Giuffre has already produced her responsive document, including bank statements showing electronic funds transfers. Accordingly, there is nothing to compel regarding this Interrogatory, and Defendant’s request should be denied. 34