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Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 9 of 12 Q. Then why you were communicating with him about statements you were making to the press? A. Insofar as this is the case, it's really all about Jeffrey, it's not a case about me. Menninger Decl., Ex. A at 392-94. As to the second point, there is simply no basis for claiming any “relationship” exists between Mr. Barden and Mr. Epstein — there is none. Again, numerous communications were produced in advance of Ms. Maxwell’s depositions relating to Ms. Maxwell’s request for input on Mr. Barden’s draft statements to the press (Menninger Decl., Ex. D), thus making any line of inquiry available to Plaintiff had she believed it were actually relevant or “key.” Regardless, Plaintiff provides no reason to claim that there is any relevance to a line of inquiry regarding an alleged relationship between Mr. Epstein and Mr. Barden. As for the final point, it is obvious from the subject line and content of the email that Ms. Maxwell was forwarding a non-privileged excerpt of a privileged communication from her attorney, Mr. Barden, to Mr. Epstein. This is certainly no basis to reopen a deposition as the document speaks for itself. D. The Reopening of Plaintiff’s Deposition is Irrelevant Plaintiff attempts to distract the Court form the legal standards required to reopen a deposition, instead arguing that she did not oppose reopening her own deposition. Of course, Plaintiff did not simply inadvertently miss two irrelevant documents in a 1,200 page production. Rather, prior to her deposition she failed to identify over thirteen (13) healthcare providers and failed to produce hundreds of pages of medical records, work records and educational records, all of which were requested prior to her deposition. She even omitted records from her current therapist and from the doctor who was (and is, apparently) prescribing substantial quantities of drugs at the time of her deposition. Indeed, Plaintiffs second deposition still cannot be