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Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 2 of 13 Plaintiff Virginia Giuffre (“Ms. Giuffre”), by and through her undersigned counsel, hereby files this Reply in Support of her Motion to Compel (DE 345). L ARGUMENT A. This Court should Order Production of Documents Responsive to Requests Nos. 1-3 Defendant characterizes the police reports (and information therein) concerning Ms. Giuffre as a minor as both “highly relevant” (Br. at 4) and “irrelevant” to this action (Br. at 5). On page 4, Defendant claims that actual police reports are “highly relevant,” stating: “the publicly available, redacted police reports are part of the record and constitute highly relevant evidence in this action.” But, on the very next page, when discussing the information gleaned from those police reports that Mr. Pagliuca had prior to the conferral call, Defendant claims the information from the police reports is “irrelevant,” stating: “The records requested are irrelevant. Plaintiff has asserted a single claim for defamation based on Ms. Maxwell’s denial of her outrageous allegations of ‘sex trafficking.’ The dispositive question is whether the denial was defamatory. RFP No. | seeks documents Mr. Pagliuca allegedly ‘reviewed and/or relied upon’ in allegedly making statements stating that Plaintiff previously made false accusations of sexual assault.” (Br. at 5). (Emphasis original). How Defendant purports to distinguish between the actual police reports as “relevant,” and the information contained in the police reports as “irrelevant,” is unexplained. However, logic would dictate that if the police reports are “relevant,” so, too, is the information contained therein and how it was acquired. For that reason, this Court should grant Ms. Giuffre’s requests Nos .1-3. Defendant states that the material responsive to Ms. Giuffre’s requests Nos. 2-3 constitute “privileged communications between (a) Ms. Maxwell’s attorneys and Ms. Maxwell, (b) defense counsel and their agents, and between (c) defense counsel with joint defense or common interest privileges concerning obtaining or receiving ‘local police[] findings or opinions’ and ‘statements 1