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Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 39 of 42 counsel’s repeated, written requests to meet and confer on various issues.’ The undersigned’s September 23, 2016, letter was simply another conferral letter that Defendant chose to ignore. Defendant’s implicitly concedes this pattern of ignoring conferral letters in her response. To support her claim that Ms. Giuffre had somehow failed to confer, Defendant writes that “[h]ad [Ms. Giuffre] bothered to follow up on this alleged communication, Ms. Maxwell would have reaffirmed that there is no ‘undisclosed’ email account.” Defendant’s Resp. Br. at 2 (emphasis added). Defendant has it exactly backwards. It is Defendant’s responsibility to be “bothered” to answer Ms. Guuffre’s initial conferral letter. Ms. Giuffre should not be expected to “follow up” with subsequent letters on the same subject, waiting for Defendant to deign to respond. Simply put, Ms. Giuffre did attempt to confer on this issue, and Defendant refused. Three weeks went by while Defendant sat on Ms. Giuffre’s letter, refusing to engage on this subject. Rather than explain why she failed to respond to (yet another) of Ms. Giuffre’s conferral letters, Defendant slyly suggests that Ms. Giuffre never sent the letter. Defendant describes the letter as an “alleged” communication, and further tells the Court that the “alleged” letter “was not included in the exhibits to the Motion.” (Resp. Br. at 1.) Yet there is no doubt that the communication was sent to, and received by, Defendant. First, the email transmittal is attached hereto at Schultz Dec. at Exhibit 2. Second, the letter itself is attached hereto at Schultz Dec. at Exhibit 3. Third, Defendant sent Ms. Giuffre a letter, dated October 17, 2016, that included multiple, word-for-word excerpts from Ms. Giuffre’s September 23, 2016, letter - an “alleged” letter that the Defendant suggests to the Court does not exist. (Defendant’s mimicking letter is ’ The following examples are some conferral letters sent by Ms. Schultz, counsel for Ms. Giuffre, that Defendant’s counsel have chosen to ignore, including: a May 20, 2016, letter regarding confidentiality designations (See DE 201); a June 8, 2016, letter regarding deficiencies in Defendant’s production; a June 13, 2016, letter regarding the same; a June 30, 2016, letter regarding search terms; and a July 14, 2016, letter regarding the same.