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Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 8 of 13 it. Defendant has produced no documents at all related to this statement made by her representative. This is a statement made to a major publication on behalf of Defendant. “Reasonable inquiry,” as required by Rule 26, Fed. R. Civ. P., would have easily yielded documents relating to this statement issued on Defendant’s behalf. Yet, Defendant did not produce documents relating to that defamatory statement, and is now caught in another discovery violation for her failure to produce documents related to that January 8, 2015, statement. Defendant cannot refuse to provide Ms. Giuffre with the extent of the publication of Defendant’s defamatory statements nor can she decide, merely, to provide self-selected documents relating to the defamatory statements Ms. Giuffre knows about at the time. Wanting to hide the fact that her defamation was on a greater scale than originally known to Ms. Giuffre is not a proper objection, and withholding from discovery Defendant’s additional defamation constitutes a discovery violation. The Court should order Defendant to fully comply with the requests in Nos. 17 and 18, including the production of documents related to the statement issued on her behalf to The Sun as reported in the January 8, 2015, article, above. E. The Documents Improperly Logged Defendant has withheld communications with Alan Dershowitz’s counsel claiming a common interest/joint defense privilege. As stated above, Defendant claims that there exist no joint defense agreement between her and Mr. Dershowitz. (Br. at 9). Yet, Defendant has agreed to provide non-party Dershowitz all the discovery materials in this case, and Dershowitz has clearly agreed to assist Defendant in this litigation. It is Ms. Giuffre’s position that an agreement must still be evidenced in order to invoke the common interest/joint defense privilege by affidavit or similar evidence. See Von Bulow by Auersperg v. Von Bulow, 811 F.2d 136, 147 (2d Cir.), cert. denied, 481 U.S. 1015, 107 S.Ct. 7