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Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 4 of 13 make that showing. “Such showings must be based on competent evidence, usually through affidavits, deposition testimony, or other admissible evidence.” Egiazaryan v. Zalmayev, 290 F.R.D. 421, 428 (S.D.N.Y. 2013) (citations omitted). Defendant has put forth no affidavits or testimony, but, instead, filed declarations of counsel for Epstein and Dershowitz, indicating their “belief” that a common interest exists.’ Should the Court consider these declarations to be “competent evidence” to establish that a joint defense agreement exists between Defendant and Dershowitz and Epstein (though neither declaration state that an agreement exists), Ms. Giuffre submits that it should not have taken motion practice to elicit such “evidence” as it is Defendant’s burden to produce this evidence. Second, these agreements are plainly relevant to the defamation claim in this case. This Court has previously ordered Defendant to produce emails in which both Epstein and Dershowitz were active in assisting Defendant draft defamatory statements against Ms. Giuffre. See April 15, 2016 Order. Defendant has set forth the defense that her defamatory statements are “substantially true,” and “cannot realistically have cause impairment to Plaintiffs reputation.” The emails between and among Defendant, Epstein, and Dershowitz, show that that the three of them conspired specifically to damage Ms. Giuffre’s reputation. They also reveal that Defendant’s defamatory statements are not “substantially true.” The joint defense agreement(s) show Defendant’s ongoing and continued relationship with Dershowitz and Epstein, which is relevant to her defenses. Both of these individuals had a hand in Defendant’s statements to the public. At the very least, the Court should conduct an in camera review of any joint defense agreements that exist to determine their relevance to both the defamation claim and the multiple affirmative defenses offered by Defendant. See Steuben Foods, Inc. v. GEA Process Engineering, Inc., 2016 ' Strangely, Defendant redacted both the names of counsel and the names of Epstein and Dershowitz in these filings.