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Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 1 of 22 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. / PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION FOR PROTECTIVE ORDER REGARDING FINANCIAL INFORMATION Plaintiff, Virginia Giuffre, by and through her undersigned counsel, files this Response in Opposition to Defendant’s Motion for a Protective Order Regarding Financial Information (DE 370). Defendant’s financial information is highly relevant to this case, particularly in light of Ms. Giuffre’s punitive damages claim as well as press reports suggesting that the Defendant may be selling her assets in New York and transferring the money outside the jurisdiction. Accordingly, Defendant’s motion for a protective order should be denied.' L PRELIMINARY STATEMENT As recounted by Defendant (DE 370 at 1-3), Ms. Giuffre has served discovery requests on Defendant, seeking certain financial information from the Defendant. The requests are narrowly tailored to the time frame related to this case, as the requested information concerns * Contemporaneous with the filing of this response to Defendant’s motion for a protective order regarding financial information, Ms. Giuffre has also filed a motion to compel Defendant to produce the requested financial information. This parallel filing is apparently required because Ms. Giuffre does not simply seek the negative relief of denial of Defendant’s requested protective order but also the affirmative relief of a Court order requiring production of the materials.