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Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 19 of 22 (DE 62). As this Court has previously explained, in allowing discovery of financial information for punitive damage purposes, “any privacy interests defendants may have in confidential financial information produced to plaintiffs can be secured by the protective order issued by this Court.” Hamm vy. Potamkin, No. 98 CIV. 7425 (RWS), 1999 WL 249721, at *2 (S.D.N.Y. Apr. 28, 1999). Nothing in Defendant’s motion establishes that Ms. Giuffre should be barred from the kinds of ordinarily discovery that often accompanies cases in which the financial dealings of a defendant are discoverable. This argument is also belied by the fact that Defendant sought, and received, Ms. Giuffre’s personal financial information. Specifically, she sought any payment information relating to the media. See Defendant’s First Set of Requests for Production at No. 30. Ms. Giuffre provided documents responsive to this request, which included her personal bank records. Defendant takes the contradictory and self-serving position that discovery concerning the personal finances of Ms. Giuffre is appropriate, yet discovery concerning her own finances is somehow inappropriate. At the very least, the Defendant should be required to produce a “statement of [her] total net worth and listing [her] income, assets, and liabilities for the [relevant] years,” as this Court ordered in a previous case. Hamm v. Potamkin, No. 98 CIV. 7425 (RWS), 1999 WL 249721, at *3 (S.D.N.Y. Apr. 28, 1999). But because that formulation came from an earlier case involving reputable corporate entities with (apparently) audited financial statements, the discovery here should be much broader — and should include all of the significant requests made by Ms. Giuffre. For example, Defendant should also be required to identify all financial transactions involving (directly or indirectly) Jeffrey Epstein, the Clinton Foundation, Ellmax LLC, The TerraMar Project, and any other person listed in the Rule 26 disclosures of either side in this case. Transactions with potential witnesses in this case are highly relevant to bias and other trial 19