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Case 1:15-cv-07433-LAP Document 1330-8 Filed 01/05/24 Page 3 of 10 Ms. Giuffre’s multiple and expensive attempts to serve Mr. Gow with a Rule 45 subpoena through the Hague Convention and various other means (Defendant’s attorney refused to accept service) recently culminated in an English Court commanding Gow to sit for his deposition by November 1, 2016. Accordingly, a follow up deposition of Defendant is critical. It is necessary both to ensure that she answers the questions she refused to answer, (as set forth in Plaintiffs Motion to Direct Defendant to Answer Deposition Questions (DE 314/356)), and to ensure that Ms. Giuffre can ask Defendant questions about the critical and late produced e-mail communications with her press agent, Ross Gow, and with her former boyfriend, convicted pedophile Jeffrey Epstein. Indeed, Defendant cannot credibly oppose Ms. Giuffre’s request because Defendant herself previously sought and received a deposition based on newly produced documents. Defendant previously argued before this Court that Ms. Giuffre’s deposition should be reopened, in part, because Ms. Giuffre obtained and produced certain documents that Defendant wanted to ask her about after Ms. Giuffre’s deposition was taken. Specifically, Defendant’s motion stated “Plaintiff's production of key documents after her deposition necessitates additional examination.” See (DE 230) at 3. Defendant’s brief continued: “All of the new information that has come to light . . . justifies the reopening of Plaintiff's deposition.” /d. at 5-6. The Court granted Defendant’s motion in a sealed Order that stated: “The deposition of the Plaintiff was held on May 3, 2016, and thereafter the Plaintiff produced additional documents and made supplemental responses . . . The Plaintiff may be questioned about any documents produced subsequent to the May 3 deposition relating to employment and education.” See Sealed August 30, 2016 Order. As the Court has already ruled that reopening a deposition is appropriate