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Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 18 of 21 Even turning to the later time period when Ms. Giuffre wrote her journal, Defendant has better records than the journal which she can review — .e.g., the psychological records specifically naming the Defendant as involved in Ms. Giuffre’s sexual abuse and Ms. Giuffre’s 141-page manuscript. Against this backdrop of many other available materials, the burned journal is obviously nothing more than cumulative corroborating evidence. Second, with regard to Defendant’s second, fallback argument regarding the dream journal (which Ms. Giuffre has diligently searched for but been unable to locate), nothing suggests it contains any relevant content. Perhaps Defendant is going to argue that Ms. Giuffre’s dreams are somehow inconsistent with her sworn testimony, but this would be pseudo-science that has no place before the jury. Cf’ SIGMUND FREUD, THE INTERPRETATION OF DREAMS (1889) (developing theory of the unconscious with respect to dream interpretation). Defendant’s brief gives no hint as to what purpose notes about dreams could have in this litigation. Cf United States v. Aleshire, 2014 WL 11394905, at *6 (W.D. Wis. Oct. 20, 2014) (“dreams themselves, however, would not be admitted”). In any event, Ms. Giuffre diligently attempted to locate these notes but could not find them. C.f Treppel v. Biovail Corp., 233 F.R.D. 363, 374 (S.D.N.Y. 2006) (“Even in a case involving exclusively hard copy documents, there is no obligation on the part of a responding party to examine every scrap of paper . . . Rather, it must conduct a diligent search, which involves developing a reasonably comprehensive search strategy.”). And there is no evidence that the dream journal was lost during (or even shortly before) the pendency of this litigation. If anything, Defendant’s argument about the dream notes shows how far afield she had to go from the core issues in this case. Recall the basic outlines of this case: Ms. Giuffre filed a court document alleging that she had been sexually abused by Defendant and others. Defendant 15