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Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 10 of 12 scheduled because Plaintiff persists in her failures to provide complete medical records. Despite Plaintiff's September 21, 2016 Motion for Court Approval of Plaintiff's Certification of Production claiming that she has completed production of medical records and emails, Plaintiff sent a release for health care information from her insurance companies on October 10, 2015 (Menninger Decl., Ex. E [GIUFFRE009094-009102])— a release and records that were requested in April. To date, those (and many other) records have not been produced. Moreover, Plaintiff made substantive and completely contradictory changes to her deposition testimony in errata sheets after the conclusion of her deposition. As well, she was instructed by counsel not to answer questions about false statements published in the media attributed to her that were critically relevant and she refused to answer the questions. She later conceded no privilege precluded her answers, and that is among the reasons she agreed to sit for a second deposition. Unlike Plaintiff, Ms. Maxwell had no opportunity to depose Plaintiff on multiple and critical issues including unproduced medical records, and undisclosed treatment providers, undisclosed educational history, undisclosed employment, undisclosed intervening causes of her alleged emotional distress, her material contradictory changes to testimony, and any statements published and attributed to her by the media she admits are false. Ms. Maxwell did not request to reopen the deposition to seek cumulative, duplicative and/or irrelevant information. The two situations are vastly different and cannot be compared. WHEREFORE, Defendant Ghislaine Maxwell requests that Plaintiffs Motion to Reopen her Deposition and permit a third deposition be denied.