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Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 6 of 22 punishment or deterrence resulting from a judgment is to some extent in proportion to the means of the guilty person.” Restatement (Second) of Torts § 908, cmt. e (1979). Defendant does not attempt to quarrel with the proposition that her vast wealth is relevant to Ms. Giuffre’s punitive damages claim. See, e.g., DE 370 at 6 (citing case allowing information about a defendant’s wealth to be presented to the jury). Instead, it appears that her only argument concerns the timing of the disclosure of such information, an issue discussed below. For purposes of setting out the salient facts, then, it is enough to note here that even Defendant has to ultimately concede that discovery about her financial information is relevant to this case. IL. DISCUSSION Because discovery regarding Defendant’s financial circumstances and recent transactions is relevant to this case for multiple reasons, Ms. Giuffre is entitled to discovery regarding that information. Under Federal Rule of Civil Procedure 34(a), a party may request that another party produce documents in her possession so long as the documents are within the scope of Fed. R. Civ. P. 26(b), which allows for broad discovery regarding any non-privileged matter that is relevant to any party’s claim or defense. Information within this scope of permitted discovery need not be admissible in evidence to be discoverable. Relevance is still to be “construed broadly to encompass any matter that bears on, or that reasonably could lead to other matter that could bear on” any party's claim or defense. State Farm Mut. Auto. Ins. Co. v. Fayda, No. 14CIV9792WHPJCF, 2015 WL 7871037, at *2 (S.D.N.Y. Dec. 3, 2015) (granting motion to compel). For reasons explained above, the financial information sought is relevant to issues in this case, and, accordingly Defendant’s motion for a protective order should be denied. There is also no sound reason for delaying discovery on these issues.