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Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 36 of 42 hasn’t been completed correctly.”) Ms. Giuffre had to then litigate, extensively, to force Defendant to perform a proper collection and search, and, correctly, in response to the Motion to Compel, this Court directed Maxwell to gather all of her electronic data and run designated search terms. See August 9, 2016, Order (DE 352) directing Defendant to gather her electronic data and run search terms. Ms. Giuffre also had to litigate for documents Defendant withheld on a wrongful claim of privilege, many of which were not privileged on their face. Ultimately this Court directed Defendant to produce these documents. (April 15, 2016, Sealed Order granting in part Motion to Compel for Improper Claim of Privilege). Remarkably, Defendant complains in her brief about the inconvenience caused by the Court ordering her to search her electronic documents (Resp. Br. at 3). But such a routine search is merely Defendant’s basic obligation under Rule 26 and Rule 34. Ms. Giuffre should not have been forced to seek a Court Order to get such obviously relevant materials from Defendant. The Federal Rules of Civil Procedure are designed in such a way as to disallow parties to hide relevant information, including the non-disclosure of potential sources of discoverable information, like Defendant’s email address on Epstein’s private server. As noted by Magistrate Judge Francis, “The overriding theme of recent amendments to the discovery rules has been open and forthright sharing of information by all parties to a case with the aim of expediting case progress, minimizing burden and expense, and removing contentiousness as much as practicable.... If counsel fail in this responsibility—willfully or not—these principles of an open discovery process are undermined, coextensively inhibiting the courts ability to objectively resolve their clients' disputes and the credibility of its resolution.” U.S. Bank Nat. Ass'n v. PHL Variable Ins. Co., 2013 WL 1728933, at *7 (S.D.N.Y.,2013) (Internal citations and quotations