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Case 1:15-cv-07433-LAP Document 1330-23 Filed 01/05/24 Page 7 of 9 standards to the parties’ privilege logs, explaining “what’s good for the goose is good for the gander.”). Well-reasoned precedent, as well as the facts in this case, requires the re-opening of Defendant’s deposition. Accordingly, the Court should grant Ms. Giuffre’s request to reopen Defendant’s deposition to answer questions relating to her lately produced documents. C. Ms. Giuffre’s Motion is Not Untimely Without any supporting case law or authority, Defendant has the gumption to argue that Ms. Giuffre’s motion is somehow “untimely” when it was the Defendant who withheld these critical e- mails during the entire discovery period, denying Ms. Giuffre the benefit of being able to use these e- mails at multiple witness depositions. The only “untimeliness” claim that can be made here is against the Defendant. The two emails in question are responsive to a Request for Production served on Defendant on February 2, 2016. Defendant produced these two emails on August 16, 2016, after her deposition and after the fact discovery period closed on July 29, 2016 (D.E. 317). Defendant wrongly suggests to this Court that the fact discovery closure date was September 8, 2016 but that is incorrect. The only deadline modified to September 8, 2016, was the expert disclosure deadline. (D.E. 413). Defendant’s documents were clearly produced after the close of fact discovery. The only party that is untimely here is the Defendant. Ill. CONCLUSION For the foregoing reasons, and the reasons set forth in the moving brief, Ms. Giuffre respectfully requests that this Court Reopen Defendant’s deposition to (1) answer lines of questions discussed in Ms. Giuffre’s Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions Filed under Seal (DE 315) which is pending before the Court; and (2) answer questions related to the two key late produced documents. 7