Giuffre_Maxwell_Batch5_p00141.png

Case 1:15-cv-07433-LAP Document 1330-8 Filed 01/05/24 Page 4 of 10 when where important documents are produced after the deposition is completed, the same relief is appropriate for Ms. Giuffre upon this motion. IL. ARGUMENT The same standard set forth in the Court’s August 30, 2016, Order applies to Defendant’s post-deposition production of key documents. Defendant’s late production of two key documents similarly “necessitates” and “justifies” the reopening of Defendant’s deposition for questioning upon them. Therefore, Ms. Giuffre should receive the same relief from the Court that Defendant obtained: the reopening of Defendant’s deposition to answer questions about these key documents. See Wesley v. Muhammad, 2009 WL 1490607, at *5 (S.D.N.Y. 2009) (“while defendants' delay in producing documents may have interfered with the completeness of depositions, plaintiff will be free to reopen any depositions for which he deems the newly produced documents to be a relevant source of questions”); Ganci v. U.S. Limousine Serv., Ltd., 2011 WL 4407461 at *2 (E.D.N.Y. Sept. 21, 2011) (“Courts will typically reopen a deposition where there is new information on which a witness should be questioned”’). Moreover, it was after Defendant’s deposition was complete, and after the briefing to reopen her deposition (on other grounds) was complete, and after discovery closed, that Defendant produced these key documents. Ms. Giuffre should be allowed to ask Defendant questions concerning them. A. The Gow Email These documents are of particular importance because one is an email communication from her agent, Ross Gow to Defendant that took place after the commencement of this litigation. It states: “Hi Ghislaine and Philip [sic] Please advise how you wish to respond... Best Ross.” GM_01141. Ms. Giuffre did not have the opportunity to question Defendant about the