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Case 1:15-cv-07433-LAP Document 1330-8 Filed 01/05/24 Page 7 of 10 Defendant did not produce her response to Gow’s email. Additionally, since the communication appears to directly contradict her deposition testimony as well as her responses to Requests for Admission, Ms. Giuffre should be entitled to use this post-litigation communication, where Gow asks Defendant, “Please advise how you wish to respond,” to cross Defendant on her prior deposition answers. An email in which Gow is actively soliciting instructions for how to make a public response to the media is evidence that Defendant is, in fact, involved in, and consulted about, what her press agent says on her behalf. B. Communication with Jeffrey Epstein Similarly, the email with Epstein regarding a reply to “one further allegation,” shows that Defendant is active in shaping her public statements regarding Ms. Giuffre, and giving drafts to Epstein for his approval. Accordingly, Defendant was never deposed on (1) why she was seeking Epstein’s permission for having Barden make a “reply;” (2) what Epstein’s relationship was with Barden; (3) or who drafted the original communication at the bottom of the email, as it does not appear to have been created by either Defendant or Epstein. C. Ms. Giuffre Did Not Oppose the Relief Sought When Defendant Brought The Same Motion and the Court Ruled that this Relief was Appropriate As the Court will recall, Ms. Giuffre did not oppose the relief sought in Defendant’s motion to reopen her deposition. (““Ms. Giuffre agrees to reopen the deposition for a limited amount of time, and for discrete lines of questioning.” DE 259 at 1). And, Ms. Giuffre specifically agreed to the relief of answering questions about, inter alia, documents produced after her deposition: “Ms. Giuffre agrees to reopening the deposition for certain questions related to the following: 1) Any medical care records that were produced subsequent to her deposition.” (DE 259 at 12). Accordingly, as Defendant sought and received the same relief upon her motion, which was unopposed by Ms. Giuffre, Defendant can put forth no valid argument against re-