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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 46 of 50 these documents. And, again, Defendant puts forth no case law in support of her position to compel. The Court should deny this request. D. Request for Production No. 10 This request seeks the same documents as Request No. 9 with regard to the Dershowitz litigation.” Defendant sets forth no new or differentiated argument with regard to this request, and Defendant puts forth no case law in support of her motion to compel Request for Production No. 10. This request has nearly all of the same defects as Request No. 9. For the reasons stated above, it should be denied. E. Requests for Production No. 11 and No. 12 With these requests, Defendant seeks “statements” obtained from witnesses in the CVRA case and the Dershowitz case, described above. This request directly targets privileged documents. In this discussion, Defendant puts forth her one and only example of case law. However, Defendant’s District of Ohio case is not applicable. It holds that affidavits are not normally protected as work product. Even should this Court adopt this premise, and adopt Defendant’s argument, there are not affidavits to produce. Based on the best of their recollection, Ms. Giuffre’s counsel do not have any affidavits that are (1) not part of the docket/filings in the CVRA case in the Southern District of Florida, or (2) not already produced to Defendant in this litigation. Even looking for such documents it would require the review of hundreds of thousands of documents which would take hours upon hours of attorney time. Again, the CVRA case centers "7 While the CVRA case was moving forward in the Southern District of Florida on behalf of Jane Does | and 2, separate litigation developed between the pro bono attorneys who had filed the lawsuit (Cassell and Edwards) and Dershowitz. After Cassell and Edwards filed the joinder motion in the CVRA case, Dershowitz took the airwaves to attack not only Jane Doe 3’s allegations against him, but also Cassell and Edwards’ decision to file the allegations. Cassell and Edwards then filed a state law defamation action against Dershowitz in Broward County, Florida. Ultimately, Cassell, Edwards, and Dershowitz agreed to settle their defamation case. 40