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Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 17 of 21 because it had not been previously notified of any injury that might reasonably lead to litigation and no litigation had been threatened); Brigham Young Univ. v. Pfizer, Inc., 282 F.R.D. 566, 572 (D. Utah 2012) (rejecting argument that Pfizer’s duty to preserve extended back to earlier, unrelated litigations). The Pfizer court further explained: “In addition, the duty to preserve only extends to documents relevant to the claim of which the party has notice.” In re Pfizer Inc. Securities Litigation, 288 F.R.D. at 317 (emphasis added). To the extent Ms. Giuffre’s 2011-2012 journal is somehow relevant to the claim at issue in this case, there was no duty to preserve because the defamation claim against Defendant did not arise until 2015 and the earlier case involved a different issue. Similarly, Defendant makes no showing that Ms. Giuffre had possession of the dream journal during 2015, nor that it is relevant such that any duty attaches to it. F. Defendant Can Show No Prejudice and She Has the “Best Evidence” Still another fatal problem for Defendant’s argument is that she has received substantial information parallel to the journal Ms. Giuffre kept. Defendant has thus suffered no prejudice. As the Court is aware from previous discovery motions, Ms. Giuffre has produced a vast amount of material in this matter, including materials from the time of her abuse and from the time she kept her journal. Of particular note are a 141-page draft manuscript she wrote in 2011, around the same time as the journal, as well as numerous e-mail communications, and even pictures and travel receipts from the years 2000-2002. Of course, the materials from 2000-02 (photos, travel records, flight logs, etc.) were all created contemporaneously with Ms. Giuffre’s abuse, and would thus serve as the “best evidence” of what was happening then. (The Court will no doubt recall Defendant’s failing memory concerning events that happened at that time, such as Defendant’s failure to be able to recollect even one of the 23 flights on which she is listed as having traveled with Epstein and Ms. Giuffre, during the time Ms. Giuffre was a minor child.) 14