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Case 1:15-cv-07433-LAP Document 1330-8 Filed 01/05/24 Page 1 of 10 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFFE’S MOTION TO REOPEN DEFENDANT’S DEPOSITION BASED ON DEFENDANT’S LATE PRODUCTION OF NEW, KEY DOCUMENTS Plaintiff, Virginia Giuffre, by and through her undersigned counsel, files this Motion to Reopen Defendant’s Deposition Based on Defendant’s Production of New, Key Documents because Defendant produced documents subsequent to her deposition about which she should answer questions. The Court has already ruled that reopening a party deposition is appropriate where important documents are produced after the deposition is completed. Accordingly, the Court should grant Ms. Giuffre’s request to reopen Defendant’s deposition to answer questions relating to her lately produced documents. L BACKGROUND The Court will recall Defendant’s case-long, unjustified recalcitrance regarding her testimony. She first attempted to avoid her deposition (causing unnecessary motion practice), and, then, she failed to answer questions at her deposition, upon which the Court ordered her to sit for her deposition again. Specifically, Ms. Giuffre started her quest to obtain Defendant’s deposition back on February 2, 2016, by serving a Notice of Deposition. Defendant filed a 1