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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 48 of 50 Finally, if Defendant is now seeking sworn affidavits, there is no practicable way to search for those things. As stated above, upon counsel’s best memory, any affidavits are part of the CVRA case docket or already produced in this litigation. If there happen to be others, to search for them, through 8 years of litigation, would certainly be a Herculean task, and not one that would necessarily yield any responsive documents. Defendant’s requests are poorly drafted. Defendant’s arguments are unavailing. And, Defendant’s sole case does not go to this request regarding “statements.” Even an attempt at compliance would be grossly overly burdensome. The Court should deny Defendant’s motion to compel with regard to these requests. VI. CONCLUSION Defendant’s brief is bereft of case law, lacking the authority upon which this Court can grant her overly-broad requests, many of which have already been fully satisfied. Similarly, Defendant’s motion for sanctions is completely baseless, and should be denied. For the foregoing reasons, Ms. Giuffre respectfully requests Defendant’s Motion to Compel and for Sanctions be denied in its entirety. DATED: August 17, 2016. Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Meredith Schultz Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 42