EXHIBIT Case Document Filed Page of United States District Court Southern District of New York Virginia Giuffre Plaintiff No Ghislaine Maxwell Defendant PLAINTIFF?S SECOND AMENDED SUPPLEMENTAL RESPONSE AND Plaintiff hereb-19.4y serves her second amended supplemental responses and objections to Defendant?s First Set of Discovery17.9 Requests GENERAL OBJECTIONS Defendant?s First Set of Discovery17.9 Requests violates L22ocal Civil Rule Defendant has served interrogatories that are in direct violation of that Rule because the interrogatories are not restricted to those seeking names of witnesses with knowledge of information relevant to the subject-250.7matter of the action the computation of each category23 of damage alleged and the existence custodian location and general description of relevant documents including pertinent insurance agreements and other evidence or information of a similar nature Local Civil Rule a I)23.6nstead they20.5 seek information under subsections and of Local Civil Rule and therefore they19.2 should not be served because they21 are not a more practical method of obtaining the information sought than a request for production or a deposition and because they20.3 were served in advance of the period day20.3s prior to the discovery20.8 cut-off date Case Document Filed Page of Local Civil Rule The interrogatories served violate Local Rule and we ask that immediatel-21.7y withdraw those interrogatories See Rule Local Rules for the Southern District of New York see also-249.3Shannon New York City Transit Auth No Sweet WL at S.D.N.Y Mar accord Gary Friedrich Enterprises LLC Marvel Enterprises Inc No BSJ JCF WL at S.D.N.Y Apr Specificall)-20.1y Rule provides a 1649.4Unless otherwise ordered the Court at the commencement of discovery22.1,-9.8 interrogatories will be restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action the computation of each category20.3 of damage alleged and the existence custodian location and general description of relevant documents including pertinent insurance agreements and other evidence or information of a similar nature 1590During discovery19.6 interrogatories other than those seeking information described in paragraph a above be served if they more practical method of obtaining the information sought than a request for production or a deposition or if ordered the Court the conclusion of other discovery20 and at least day20.3s prior to the discovery20.3 cut-off date interrogatories seeking the claims and contentions of the opposing party20.1 be served unless the Court has ordered otherwise Similarly30.7 Requests for Production numbers i and also violate Local Rule in that they20.7 on the offending interrogatory20.2 requests Rule provides that a part-21y must first try20 to obtain discovery20.7 through document production and testimony31.3 Discovery19.8 does not close in this case until July30.2 and Defendant has not noticed a deposition As such these-245interrogatories violate L21.4ocal Rule and are premature Defendant?s First Set of Discovery17.7 Requests also violates Rule Fed Civ which provides a part-21.6y serve on other part-22.2y no more than interrogatories including all discrete subparts that Defendant has served a total of interrogatories including subparts Case Document Filed Page of in violation of Rule We ask that y20ou immediately20.9 withdraw those interrogatories that exceed the interrogatory21.5 limit set Rule Ms Giuffre objects to Defendant?s First Set of Discovery17.8 Requests to the extent they30 seek information that is protected 10applicable privilege including but not limited to attorney20.6 client privilege work product privilege joint defense/common interest privilege 10.5public interest privilege and other applicable privilege Ms Giuffre objects to the requests to the extent Defendant?s First Set of Discovery21.1 Requests call for the production of documents or information that is already22.9 in the possession custody20.3 or control-251.9of the Defendant Ms Giuffre further objects to the requests to the extent that Defendant?s First Set of Discovery17.6 Requests is duplicative of documents and information that can equally21.5 or more readily21 be obtained the Defendant Ms Giuffre objects to the requests to the extent that they21.3 seek documents that are not relevant material or necessary20.7 to this action and thus are not reasonabl-21.1y calculated to lead to the discovery20.5 of admissible evidence Many20.1 of the requests in the Defendant?s First Set of Discovery20.4 seek documents that are in no way19 limited to their relation to this case Indeed they20.1 seek documents that are not important to resolving the issues documents that are not relevant to any20 part-22y?s claim or defense and documents that are not proportional to the needs of the case Such requests create a heavy21.2 burden on Ms Giuffre that outweighs benefit Such discovery20.6 is prohibited the Federal Rules of Civil Procedure particularl-16.9y under the amendments to Rule Fed and is wholly19.9 inappropriate Ms Giuffre objects to the requests to the extent that they21.5 are overl-21.7y broad and unduly19.1 burdensome as individually19.5 logging all privileged responsive documents would be burdensome Plaintiff contends that requests targeting such privileged information are overly20.5 Case Document Filed Page of broad under Rule Fed Civ 247Specifically20.8 Ms Giuffre objects to the requests as overly20.2 burdensome to the extent that they19.6 would require logging voluminous and ever-increasing privileged communications between Ms Giuffre and her counsel after the date litigation commenced on September Giuffre objects to the requests as overly19.9 burdensome to the extent that they21 would require logging voluminous privileged documents between Ms Giuffre and her counsel related to Jane Doe and Jane Doe United States Case no pending in the Southern District of Florida Bradley Edwards and Paul Cassell Alan Dershowitz Case no CACE pending in the Seventeenth Judicial Circuit Broward County19.6 Florida and Jane Doe No Jeffrey Epstein Case No Southern District of Florida Accordingl-22y due the undue burden of individually30.3 logging responsive privileged documents related to Defendant?s overl-20.8y broad requests Plaintiff has employ20.1ed categorical logging of such privileged responsive documents pursuant to L21.5ocal Civil Rule Ms Giuffre objects to the requests in that they19.2 seek to invade her privacy20.4 for the sole purpose of harassing and intimidating Ms Giuffre who was a victim of sexual trafficking Ms Giuffre objects to the requests to the extent they20.9 are overl-21.7y broad and unduly burdensome Ms Giuffre objects to Defendant?s definition of your attorney19.9s because it includes names of attorney20.5s that do not represent her including Spencer Kuvin and Jack Scarola Ms Giuffre?s responses to Defendant?s First Set of Discovery15.8 Requests are being made after reasonable inquiry20.1 into the relevant facts and are based upon the information and documentation that is presently19.8 known to her Ms Giuffre reserves the right to modify30.8 and/or supplement her responses Ms Giuffre is producing documents and information herewith and she will continue to review and produce relevant documents until completion Case Document Filed Page of Ms Giuffre incorporates her above-listed general objections in the responses herein INTERROGATORIES present residential address residential address You have had since including residential treatment facilities dates You lived at each address other Persons lived with You at 9.9each address and 10for what period of time they20.8 lived at such address Response to Interrogatory One Ms Giuffre objects to this interrogatory18.1 in part because it violates Rule Ms Giuffre objects to this interrogatory20.4 in that it seeks information that is sought Defendant only20.9 to harass and intimidate Ms Giuffre who was a victim of sexual trafficking Per the Plaintiff?s First Responses and Objections and-248.8per our representations during the March meet and confer phone call we are working diligentl-17.4y to find information to supplement the below information with regard to address and dates and once that information is obtained Plaintiff will serve supplemental responses Additionally21 per the March meet and confer phone call we are addressing with the Plaintiff whether she will reveal here address to Defendant?s counsel confidentially20.6 9.7and we will update with her response to 10.1concerns with respect to Ms Giuffre and her minor children she is not at liberty19.5 to reveal her present residential location To ensure that Defendant is not prejudiced the failure to provide information about Ms Case Document Filed Page of Giuffre?s specific residential location Ms Giuffre agrees to have her attorney20.6?s accept service on her behalf of necessary19.5 communication or filings in this matter to be addressed to Sigrid McCawley17.6 Esq Boies Schiller Flexner East Las Olas Blvd Suite Fort Lauderdale FL Giuffre can recall living at the following addresses during the period of to the present Ms Giuffre have lived at other locations for which she does not presentl-22.1y have the address Ms Giuffre is providing the information she has presently19.9 to the best of her recollection and review of documents and will supplement to the extent she obtains additional information responsive to this interrogatory21.1 Giuffre believes she has lived at the following residences In Januar-17.2y Ms Giuffre was old Ms Giuffre recalls one facilit-20.8y named Growing Together that was located in or around Palm Beach but she does not recall the dates when she resided at the facility21.7 From Ms Giuffre lived and travelled-259.9with Jeffrey19.6 Epstein and stay20.2ed at his various mansions in New 71st Street New York NY Palm Beach El Brillo Palm Beach Florida New Mexico Zorro Ranch Zorro Ranch Rd Stanley21 New Mexico L11.3ittle St James Red Hook Quarters Suite B3 Case Document Filed Page of St Thomas Virgin Islands and Paris Avenue Foch Apt 2DD Paris France Jeffrey20.5 Epstein also rented a residence for Ms Giuffre in Roy20.6al Palm Beach the exact address and dates of renta7.9l are in the possession custody20.7 and control of Jeffrey19.4 Epstein Tony20.3 Figueroa James Michael Austrich and a few other individuals for whom Ms Giuffre cannot recall the names of stay20.3ed with her from time to time at the residence that Jeffrey20.5 Epstein rented Ms Giuffre?s parents address was Rackley Road L20.7oxahatchee Florida and she lived there from time to time with her mother her father and her brothers 2C Quentin St Basshill NSW in approximately21.2 but she is not certain of that date At this location Ms Giuffre lived with Robert Giuffre Paramentata NSW from approximately30.6 but she is not certain of those dates At this location Ms Giuffre lived with Robert Giuffre Blue NSW from approximately30.3 is not certain of those dates At this location Ms Giuffre lived with Robert Giuffre Elk St NSW from approximately29.4 but is not certain of those dates At this location Ms Giuffre lived with Robert Giuffre Robertson Road Bass-10.4hill NSW from through January of At this location Ms Giuffre lived with Robert Giuffre Case Document Filed Page of B8.2u1.2ndeena Rd Glenning Valley22 NSW from approximately30.9 January21.2 of through October At this location Ms Giuffre lived with Robert Giuffre Winchester Drive Titusville from approximately31.5 November to October of At this location Ms Giuffre lived with Robert Giuffre Street Penrose CO from approximately21 October of through October At this location Ms Giuffre lived with Robert Giuffre address email account cellphone number and cellphone provider social media account and login or screen name text or instant messaging account name and number that You have used applied for or been supplied between and the present Response to Interrogatory No Ms Giuffre objects to this request in that it violates Rule Ms Giuffre objects to this request in that it is 8.5broad and seeks information and intimidate Ms Giuffre For the period of to the present Ms Giuffre provides the following information During the time period that she was 7.9trafficked by23 Jeffrey22.5 Epstein and the defendant the defendant provided Ms Giuffre with a cellphone so that she could be reached the Defendant and Jeffrey22.8 Epstein at any time Defendant is in possession of the information relating to this cellphone that she provided to Ms Giuffre Ms Giuffre is responding with the information she 8.4recall but to the extent she obtains additional information she will supplement this response Ms Giuffre?s e-mail address is robiejennag y247mail.com She can recall having the following cell Ms Giuffre had a Case Document Filed Page of Facebook account for a short time but it is no longer active Per our representations during the March meet and confer phone call we are working diligently19.3 to find information to supplement the above information and once that information is obtained Plaintiff will serve supplemental responses each attorney21.8 who has represented from to the present the dates of an-19y such representation and the nature of the repre8sentation Response to Interrogatory No Ms Giuffre objects to this interrogatory17.9 as it seeks privileged information relating to her representation attorney21.4s Ms Giuffre responds as follows:-253.2Bob Josefsberg Katherine Ezell Amy Ederi among oth-9.3er possible Podhurst Orseck P.A attorney17.7s-11.3 represented Ms Giuffre as a in the litigation sty31.1led as Jane Jeffrey Epstein Case No 09-80656-CIV-Marra/Johnson starting on January Stan Pottinger David Boies and Sigrid Mc6.4Cawley20.5 along with other Boies Schiller Flexner Boies Schiller attorney)20.4s represented Ms Giuffre as a non-part-21.8y in the litigation sty30.6led as Bradley Edwards and Paul Cassell Alan Dershowitz Case no Seventeenth Judicial Circuit Br7.3oward County20 Florida starting-239.4in February20.4 Brad Edwards along with other Farmer Jaffe Weissing Edwards Fistos Lehrman P.L Farmer Jaffe attorney)18.3s Paul Cassell Stan Pottinger David Boies and Sigrid McCawley20.4 along with other Boies Schiller attorney20.8s represent Ms Giuffre as a party20.6 in the litigation sty20.8led Giuffre Maxwell RWS in the Southern District of New York the complaint of which was filed in September Paul Cassell represents-260.6Ms Giuffre as a non-party20.4 in the litigation sty20.5led as Jane Doe and Jane Doe United States Case No Southern District of Florida starting in of Brad Edwards-260.6 along with other Farmer Jaffe-245.9attorney20.5s 247represents Ms Giuffre as a non-party21.1 in the litigation sty31.1led as Jane Doe and Jane Doe United States Case No Southern District of Florida starting in Case Document Filed Page of Brad Edwards provided Ms Giuffre with legal advice concerning media inquiries Ms Giuffre had received starting in Paul Cassell Brad Edwards along with other Farmer Jaffe attorney21.3s Stan Pottinger David Boies along with other Boies Schiller attorney18.7s represented Ms Giuffre regarding investigations into potential legal action starting in 8the second half of Paul Cassell Brad Edwards along with other Farmer Jaffe attorney21.3s Stan Pottinger David Boies and Sigrid McCawley19.4 along with other Boies Schiller attorney20.7s represent Ms Giuffre as a cooperating witness with regard to a law enforcement investigation starting in May20 Paul Cassell provided-249.9Ms Giuffre-245.7with legal advice concerning potential legal action-250.6starting in Paul Cassell and-248.8Brad Edwards-250.5 6.8(along with other Farmer Jaffe attorney19.2s represented Ms Giuffre and-248.3Victims Refuse Silence 7.7giving 9.6advice regarding Victims Refuse Silence starting in October Meg Garvin-249.8 law professor at Lewis Clark Law School and the Executive Director of the National Crime Victim 247.1represented Ms Giuffre and Victims Refuse Silence giving advice regarding Victims Refuse Silence starting in Sigrid McCawley20.7 along with other Boies Schiller attorney22.1s represented Ms Giuffre and Victims Refuse Silence giving advice regarding Victims Refuse Silence starting in 9.6February19.9 each Communication including the transmission of Document that You or Your Attorney29s have had with local state or federal law enforcement agent or agency21.2 whether in the United States or other country20.9 whether in Your capacity22.1 as a purported victim witness or perpetrator of criminal activity and whether as a juvenile or as an adult including without limitation date of such Communication Case Document Filed Page of form of such Communication whethe6.6r oral or written and if written the format of such Communication identities of all persons involved in the Communication including the identity30.6 of the law enforcement agency30.3 10.2with whom the agent is or was affiliated case number associated with such Communication subject matter of 10.1such Communication disposition of 10.1case 9.8associated with 10.1such Communication irrespective of whether the matter was sealed expunged or later dismissed Response to Interrogatory No Ms Giuffre objects to this interrogatory20.5 in that it 9.9violates Rule Ms Giuffre objects to this interrogatory in that it seeks 10.3protected information regarding confidential investigations Ms Giuffre objects in that it seeks information protected the attorney20--7.5client privilege the attorney20.1 10.7work product privilege joint defense/common interest privilege the public interest privilege,-10.4 other applicable privilege Giuffre objects to the this seeks information regarding sexual assaults that occurred prior to her 10.1involvement with the Defendant and Jeffrey20.1 E-8.9pstein Ms Giuffre 10responds as follows Ms Giuffre in 10accordance with the Court?s direction at the hearing on April has submitted documents to the Court for In Camera review Ms 10.7Giuffre met 10with the FBI or about 9.9March Ms Giuffre also corresponded with Maria Villafano from the U.S Attorney?s office 9.7and that correspondence has been produced each Communication that You or Your Attorney20.2s have had with author reporter correspondent columnist writer commentator investigative journalist Case Document Filed Page of photojournalist newspaper person freelance reporter stringer or other employee of media organization or independent consultant to the same9.6 including date of such Communication form of such Communication whether oral or written and if written the format of such Communication identities of all persons involved in such Communication including the identit-17.4y of the media organization with whom the agent is or was affiliated article title date of publication and means of publication of article report or re5.1-printing of such Communication made You or Your Attorney29.9s amount of that You and/or Your Attorney19.4s received in exchange for an-19y such Communication dates on which You and/or Your Attorney18.2s received such 19.1Income for such Communication Response to Interrogatory No Ms Giuffre objects to this interrogatory17.9 in that it violates-5.2 Rule Giuffre objects in that it seeks information protected the attorney20.1--6.9client privilege the attorney20.7 work product privilege joint defense/common interest privilege the public interest privilege and other applicable privilege Ms Giuffre objects in that this request is 10.2broad and burdensome Case Document Filed Page of false statements attributed to Ghislaine Maxwell which were published globall-20.7y including within the Southern District of New York as You contend in paragraph of Count of Your Complaint including exact false statement date of its publication publishing entity20.1 and title of publication containing the purportedl-22.3y false statement or internet address for internet version of such publication and nature of the publication whether in print internet broadcast or some other form of media Response to Interrogatory No Ms Giuffre objects to this interrogatory30.2 in that it violates Rule Ms Giuffre objects in that it seeks information protected the attorney20.5--7client privilege the attorney21.1 work product privilege joint defense/common interest privilege the public interest privilege,-10.5 and 10.4other applicable privilege Ms Giuffre 10.2further objects because the information requested above is in the possession Defendant who has failed to comply30.6 with her production obligations in this matter whether You believe that You have ever been defamed other than Ghislaine Maxwell so as to eac5.2h alleged act of Defamation state exact false statement date of its publication publishing entity20.1 and title of publication containing the purportedl-22.3y false statement Case Document Filed Page of or internet address for internet version of such publication and nature of the publication whether in print internet broadcast or some other form of media Response to Interrogatory No Ms Giuffre objects to this request in that it violates L20.5ocal Rule Ms Giuffre objects to this request in that it seeks information protected the attorney20.4 client and work product privileges Ms Giuffre objects to this interrogatory21.2 in that it is not limited in time or to the subject nature of this litigation the individuals referenced in Your plea5.4dings filed in the U.S District Court for the Southern District of Florida Jane Doe and Jane Doe United States of America as the high-profile non-part-22.1y individuals to whom Mr Jeffrey Epstein sexually30.7 trafficked You including-240numerous prominent American politicians powerful business executives foreign presidents a well-known Prime Minister and other world leaders including as to each episode of alleged sexual trafficking date of such sexual trafficking location of such sexual trafficking witnesses to such sexual trafficking 20I13.1ncome You received in exchange for such sexual trafficking and 10.2Documents You have to support or corroborate Your claim of such sexual trafficking Response to Interrogatory No Ms Giuffre objects to this interrogatory18.1 in that it violates L22ocal Rule Ms Giuffre objects in that it seeks information protected the attorney20.1--6.9client privilege the attorney20.7 work Case Document Filed Page of product privilege joint defense/common interest privilege the public interest privilege and other applicable Ms Giuffre objects to this interrogatory18.5 because naming some such individuals would jeopardize her safety20.5 based on credible threats to the Giuffr-6.8e refers to the list of witnesses identified in her Revised Rule Disclosures You have had from until the present including without limitation the name of Your or the name of Person who engaged You for such-249.6Employ20.7ment the address and telephone number for such Employment the beginning and ending dates of Employ20.5ment Your job title in such Employ30.2ment and Your from such Employ20.5ment Response to Interrogatory No Ms Giuffre objects to this request in that it is overly18.4 broad and undul-21.2y burdensome and seeks information that is not relevant to this case Ms Giuffre responds as follows Ms Giuffre worked-250at Mar a Lago-250.2as a locker room attendant for the spa area8.9 Records produced in this case identify20.1 the date of employment as and she recalls being there in the summer Giuffre previousl-24.3y attempted to gather emplo-17.1yment records from See Giuffre002726 She earned-249.5approximately20.3 per hour The address South Oc-7.3ean Boulevard Palm Beach Florida with the telephone number Ms Giuffre worked at Roadhouse Grill as a waitress in approximately20.7 but Ms Giuffre is unsure of the exact dates of employ19.7ment Her wages primaril-22.4y consisted of tips Ms Giuffre does not recall the location of Roadhouse Grill A Google search for Case Document Filed Page of the same an address at Southern Blv West Palm Beach FL and a telephone number of Ms Giuffre worked at Employ30.5ment Training and Recruitment-250.8Australia from approximately20.5 through January19.8 of but Ms Giuffre is unsure of the exact dates of Ms Giuffre was a receptionist earing approximately17.5 per hour to the best of her recollection Upon information and belief this corp8.5oration is currentl-20.1y20 located in a different location from the location at which Ms Giuffre was employ21.1ed Upon information and belief based on an internet search the new location of this entity17.8 is Donniforn Street Gofford NSW with a telephone number of Ms Giuffre worked at Gemma Catering/Wedding Receptions in approximately She received approximately20.2 She does not recall the name of the proprietor nor its location Ms Giuffre worked at Manway18.1 9.7L11.5ogistics in approximately30.8 Ms Giuffre recalls it located in or around Australia An internet search y31.6ielded an address of Miller Road Villawood NSW and a phone number of Ms Giuffre worked as a receptionist and earned approximately21.9 from source other than Your Employ24.7ment that You have received from January20.4 until the present including the Person or entity19.4 providing such the amount of the 10.1Income the dates on 10.3which such 9.6was received 10and the nature of the whether loan investment proceeds legal settlement asset sale gift or other source Case Document Filed Page of Response to Interrogatory No Ms Giuffre objects to this interrogatory in that it violates Rule Giuffre objects to this request in that it overly19.9 broad and seeks confidential financial information Ms Giuffre objects to this interrogatory in that it seeks information covered confidentiality21 provisions Ms Giuffre objects to this information in 9.8that p-8a-8y20ment information for the sexual trafficking she endured at the hands of Jeffrey29.9 10.3Epstein and Ghislaine Maxwell is in the possession and control of the Defendant and Jeffrey20.4 Epstein Ms Giuffre is in possession of a responsive document that contains a confidentiality provision Defendant 9.7obtains and produces to Ms Giuffre a written waiver from her conspirator Mr Epstein of the 9.7confidentialit-20.3y19.9 10.2provision freeing Ms 10.7Giuffre from liability31 whatsoever under the confidentialit-21y7 6.6p7r3.3ovision she will produce the document facts upon which You base Your contention that You have suffered as a result of the Alleged Defamation Ghislaine Maxwell past and future lost wages and past and future loss of earning capacity19.8 and actual earnings 249.7precise amounts to be computed but not less than Response to Interrogatory No Ms Giuffre objects to this interrogatory18.1 in that it violates L22ocal Rule Ms Giuffre objects to this interrogatory18.9 in that it prematurel-21.6y10 10s-11eeks expert witness disclosures Ms Giuffre incorporates 10reference herein her Revised Rule disclosures which includes her computation of damages Health Care Provider from whom You received treatment for any Case Document Filed Page of phy20.4sical mental or emotional condition that You suffered from subsequent Alleged Defamation 10.2Ghislaine Maxwell including a Health Care Provider?s name address and telephone number ty20.8pe of consultation examination or treatment provided dates You received consultation examination or treatment d.-1500.1whether such treatment was on an in-patient or out-patient basis medical expenses to date f.-1669.9whether health insurance or some other person or organization or entity22.2 has paid for the medical-260.8expenses and each such Health Care Provider please execute the medical and mental health records release attached hereto as Exhibit A Response to Interrogatory No Pursuant to this Court?s Order Ms Giuffre will provide information for health care providers from through the present Ms Giuffre continues to search for medical providers that appear in documents-8.1 Dr.-249.7Steven-249.2Olson St Thomas More Hospital Phay17.4 Avenue Canon City20.1 CO treated Ms Giuffre described in the medical records produced-251.2at Dr Mona Devansean Okeechobee Blvd Roy18.3al Palm Beach FL It appears Dr Devansean is retired We produced the letter we sent her as well as a document indicating the practice was closed at GIUFFRE005335 Case Document Filed Page of Dr Chris Donahue Clifton Village Shopping Centre Captain Hook Clifton Beach QLD is believed to have treated Ms Giuffre Ms Giuffre has sent a release to Dr Donahue and is awaiting a response Dr John Harris-251.1and Dr Darshanee at 9.9The Entrance Medical Centre The Entrance Road The Entrance treated Ms Giuffre as described in the records produced-247.3at Dr Wah Wah Central Coast Family19.6 Medicine Unit Anzac Rd Tuggerah Ms Giuffre as described in the medical records produced-250.1at Dr Sellathurai a/k/a Dr Sella Buss Hill Plaza Medical Center Hume Highway19.8 Bass Hill NSW treated Ms Giuffre as described in the medical records produced at Oaks Medical Center Knox McRae Dr Titusville was believed to have possibl-19.9y treated Ms Giuffre but Medical Center responded stating that they21.1 have no records for Ms Giuff-8.9re see Dr Carol Hay20.2ek Denison Road Dulwich Hill NSW Records have been requested but thus far have been denied Another medical release was sent and is pending New York Hospital treated Ms Giuffre as described-246.3in the medical records produced at Campbelltown Hospital Moncrleff illegible Close St Helens treated Ms Giuffre as described in the medical records produced at Case Document Filed Page of West Hospital treated Ms Giuffre as described in the medical records produced at Westmead Hospital treated Ms Giuffre on as described in the medical records produced at As Defendant requested 7.8Medical releases have been provided for Dr Karen Kutikoff Wellington I23.6maging Associates PA Growing Together Health Care Provider from whom You received treatment for p-9h-9y26sical mental or emotional condition including addiction to alcohol prescription or illegal drugs that You suffered from prior Alleged Defamation by29 Ghislaine Maxwell including Health Care Provider?s name address and telephone number ty20.8pe of consultation examination or treatment provided dates You received consultation examination or treatment d.-1500.1whether such treatment was on an in-patient or out-patient basis medical expenses to date f.-1669.9whether health insurance or some other person or organization or entity22.2 has paid for the medical expenses and each such Health Care Provider please execute the medical and mental health records release attached hereto as Exhibit A Response to Interrogatory No Ms Giuffre objects to this interrogatory18.1 in that it violates L22ocal Rule Ms Giuffre objects to this request in that it is overbroad and seeks confidential medical information of a sex Case Document Filed Page of abuse victim and is not limited in scope to the issues in this case Ms Giuffre objects in that it seeks information protected the attorney20.5--6.6client privilege the attorney21 work product privilege joint defense/common interest privilege and other applicable privilege.-256.6 Ms Giuffre objects to this request in that it is not limited in scope to the medical information relating to the abuse she suffered from Defendant and Jeffrey18.8 Epstein Person who You believe subjected You to or with whom You engaged in illegal or inappropriate sexual contact conduct or assault prior to June including the names of the individuals involved the dates of such illegal or inappropriate sexual contact conduct or assault whether Income was received You or any27.3one else concerning such event whether a police report was ever filed concerning such event and the outcome of such case as well as the address and location of such event-5.6 Response to Interrogatory No Ms Giuffre objects to this interrogatory18.1 in that it violates L22ocal Rule Ms Giuffre objects to this request in that it is overbroad and seeks confidential medical information of a sex abuse victim Ms Giuffre objects to this request in that it seeks sexual assault information for a period prior to the sexual abuse at issue in this matter for a period when she was a minor child from the time Ms Giuffre was born until she was Ms Giuffre objects to this request in that it is sought solely19.8 to harass and intimidate Ms Giuffre who is a victim of sexual abuse the defendant Case Document Filed Page of REQUESTS FOR PRODUCTION All Communications and Documents identified in Interrogatories above Response to Request No Ms Giuffre objects to this request in that Defendant?s interrogatories violate L19.6ocal Rule Ms Giuffre objects in that it seeks information protected the attorney19.8--7.2client privilege the attorney20.2 work product privilege joint defense/common interest privilege the public interest privilege5.2 and other applicable privilege.-499.8Ms Giuffre objects to this request on the grounds that it is overly20.3 broad-259.3and unduly20.3 burdensome,-249.9incorporating the interrogatories that total subparts and calls for the production of documents that are irrelevant to this action and not reasonabl-21.2y20.1 9.7calculated to lead to the discovery20.1 of admissible evidence Ms Giuffre objects to this request in that it seeks to invade the privacy21.8 rights of a sex abuse victims and is meant for the improper purpose of harassing and intimidating this victim Subject to and without waving the above objections Ms Giuffre-246is withholding production of documents that are privileged pursuant to the attorney21.9--7client privilege the work product privilege,-248.7and the public interest privilege Ms Giuffre is also withholding electronic renditions of photographs that depict the faces of her minor children including school portraits and other photographs taken that reveal the faces of her minor children Subjection to and without waiving the above objections Ms Giuffre has alread-13.6y20 produced documents Bates labelled GIUFFRE01 to and will produce non-privileged documents responsive to this Request limited to documents that do not depict images of her minor children as described supra and will continue to supplement her production Case Document Filed Page of Documents reviewed or relied upon in answering Interrogatory Nos above Response to Request No Ms Giuffre objects to this request in that violate L20.9ocal Rule Ms Giuffre objects to this request in that it seeks information that is protected the attorney20.6 client work product and public interest 8.7and other applicable privileges Ms Giuffre objects to this request in that it is overly20.3 broad incorporating the interrogatories that total subparts Ms Giuffre objects to this request in that it seeks to invade the privacy19.5 rights of a sex abuse victims and is meant for the improper purpose of harassing and intimidating this victim Subject to and without waving the above objections Ms Giuffre-246is withholding production of documents that are privileged pursuant to the attorney21.9--7client privilege the work product privilege and the public interest privilege Ms Giuffr7.1e is also withholding electronic renditions of photographs that depict the faces of her minor children including school portraits and other photographs taken that reveal the faces of her minor children Subjection to and without waiving the above objections Ms Giuffre has produced documents Bates labelled GIUFFRE01 to and will produce non-privileged documents responsive to this Request limited to documents that do not depict images of her minor children as described supra and-249.9will continue to supplement her production Documents from any law enforcement agency whether local state or federal whether in the United States or elsewhere which concern or relate to You in any way These Documents should include without limitation any witness statements including statements made by You Case Document Filed Page of Response to Request No Ms Giuffre objects to this request in that it seeks information that is protected the attorney20.6 client work product public interest privilege-242.7and other applicable privileges Ms Giuffre objects to this request in that it is not limited in time period Subject to and without waiving the above-242.4objections Ms Giuffre has already20 produced documents Bates labelled GIUFFRE01 to and will produce-245.5non-privileged documents responsive to this Request and will continue to supplement her production Ms Giuffre is withholding documents that concern or relate to currently20.8 ongoing investigation law enforcement agency20.2 under the public interest privilege and other applicable privileges Documents reflecting any letter of engagement any fee agreement or any other type of writing reflecting an engagement of any attorney identified in response to Interrogatory No Response to Request No Ms Giuffre objects to this request in that it seeks information that is protected the attorney20.7 client work product joint defense and other applicable privileges Ms Giuffre is withholding documents based on this Ms Giuff-7.4re is withholding documents reflecting the engagements between herself and her attorney20.6s she has engaged in relation to the above-captioned action and other actions-250.9as those documents involve privileged communications Documents relating to any Communications occurring from to the present with any of the following individuals or with their attorneys agents or representatives Case Document Filed Page of a.-1496.5Jeffrey Epstein b.-1436.8Ghislaine Maxwell witness disclosed in Plaintiff?s Rule a disclosures witness identified by You in response to Interrogatory No and No Roberts Roberts g.-1496.5Kimberley Roberts LNU half-7.5-brother of Plaintiff Roberts Kess Guderyon k.-1436Anthony Valladares l.-1716.2Anthony Figueroa Eppinger Response to Request No Ms Giuffre objection to this request on the grounds that it is overly21.9 broad and unduly20 burdensome particularl-19.6y as it seeks documents relating to over individuals and calls for the production of documents that are irrelevant to this action and not reasonab9.4l-12y20.2 calculated to lead to the discovery20.3 of admissible evidence Ms Giuffre objects because compliance with this request is unduly20 burdensome Ms Giuffre objects to this request in that documents responsive to this request are within the possession and control of the defendant and Jeffrey18.5 Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms Giuffre?s request seeking communications between the Defendant and Ms Case Document Filed Page of Giuffre and between J-10.2effrey20 Epstein and Ms Giuffre Ms Giuffre objects to this request to the extent is seeks documents protected the attorney client work product joint defense 6.3public interest-251.4or other applicable privilege Ms Giuffre objects to this request in that it is sought solely20.5 to harass and intimidate Ms Giuffre and invade her seeking her private communications with her various family20.1 members including aunts uncles and parents and siblings Subject to and without waving the above objections Ms Giuffre-246.4is withholding production of documents that are privileged pursuant to the attorney21.9--7client privilege the work product privilege and the public interest privilege Ms Giuffre is also withholding electronic renditions of photographs that depict the faces of her minor children including school portraits and other photographs taken that reveal the faces of her minor children Subjection to and without waiving the above objections Ms Giuffre has alread-14.5y20 produced documents Bates labelled to and will produce non-privileged documents responsive to this Request limited to documents that do not depict images of her minor children as described supra and will continue to supplement this production photographs or video containing any image of You and the following individuals To the extent You have such photographs and video in their original native format please produce them in that format not a paper copy a.-1499.7Ghislaine Maxwell Dershowitz c.-1560Jeffrey Epstein Albert Christian Edward the Duke of York aka Prince Andrew Case Document Filed Page of Eppinger Clinton g.-1499.1Stephen Hawking Gore of the individuals identified by You in response to Interrogatory No and No Response to Request No Ms Giuffre objects-400.4to this request in that documents responsive to this request are within the possession custody21 control of the defendant and Jeffrey20.9 20.1Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms Giuffre?s request seeking communications between the Defendant and Ms Giuffre and between Jeffrey20.2 Epstein and Ms Giuffre Subject to and without waiving the above objections Ms Giuffre has produced documents Bates labelled to and will produce non-privileged documents responsive to this Request and will continue to supplement her production Ms Giuffre does not have original native format as requested so she is producing the paper copies she has in her possession custody20.2 and control All photographs and video of You in any of Jeffrey Epstein?s properties including but not limited to his home in Palm Beach Florida his home in New York City New York his ranch in Santa Fe New Mexico and Little Saint-247.9James Island-254.4in the U.S Virgin Islands To the extent You have such photographs and video in their original native format please produce them in that format not a paper copy Case Document Filed Page of Response to Request No Ms Giuffre objects to this request in that documents responsive to this request are within the possession custody21 control of the defendant and Jeffrey20.9 20.1Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms Giuffre?s request seeking communications between the Defendant and Ms Giuffre and between Jeffrey20.2 Epstein and Ms Giuffre Subject to and without waiving the above objections Ms Giuffre has produced documents Bates labelled to and will produce documents responsive to this Request and will continue to supplement her production Ms Giuffre does not have original native format as requested so she is 10.4producing the paper copies she has in her 10.2possession custody20.2 control The Defendant has-580.6documents responsive to this request that she should produce All photographs or video of You in any of Ms Maxwell?s properties including her home in London England and her home in New York City New York To the extent You have such photographs or video in their original native format please produce them in that format not a paper copy Response to Request No Ms Giuffre objects to this request in that documents responsive to this request are within the possession custody21 10and control of the defendant and Jeffrey20.9 20Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms Giuffre?s request seeking communications between the Defendant and Ms Giuffre and between Jeffrey20.2 Epstein and Ms Giuffre Case Document Filed Page of Subject to and without waiving the above objections Ms Giuffre has produced documents Bates labelled to and will produce non-privileged documents responsive to this Request and will continue to supplement her production Ms Giuffre does not have original native format as requested so she is producing 16.5paper 26.4copies she has in her possession custody19.2 11.8control 9.5The Defendant has documents responsive to this request that she should produce Any Documents reflecting rental agreements or purchase agreements for the residential addresses identified by You in response to Interrogatory No Response to Request No Ms Giuffre objections to this Request on the grounds that it is overly21.1 broad and unduly19.9 burdensome and calls for the production of documents that are irrelevant to this action and not reasonabl-21.2y20.1 10calculated to lead to the discovery20.1 of admissible evidence Ms Giuffre objects to this request in that it seeks confidential financial info6.1rmation that is irrelevant to this action Ms Giuffre objects to this request to the extent is seeks documents protected the attorney20.2 client work product joint defense public interest-250.9or 10.3other applicable privilege Ms Giuffre objects to this request in that the information regarding rental agreements for the apartments that Defendant and Jeffrey20.1 Epstein rented for her are in the Defendant?s possession control and custody21.2 Subject to and without waiving the above objections Ms Giuffre 7.1has 10already20.6 produced documents Bates labelled GIUFFRE01 to GIUFFRE005353 and will produce non privileged documents responsive to this Request and will continue to supplement this production Case Document Filed Page of Documents relating to Your Employment and/or association with the Mar-a-Lago Club located in Palm Beach Florida including any application for Employment Response to Request No Ms Giuffre objects to this request to the extent is seeks documents protected the attorney20.4 client work product joint defense public interest-252.2or other applicable privilege Subject to and without waiving the above objections Ms Giuffre 7.2has already20.3 produced documents Bates labelled GIUFFRE01 to GIUFFRE005353 and will produce non privileged documents responsive to this Request and will continue to supplement this production Document reflecting any confidentiality agreement by and between or concerning You and the Mar-a-10.2-Lago Club Response to Request No Ms Giuffre objects to this request to the extent-250.8is seeks documents protected the attorney20 client work product joint defense public interest-251.4or other applicable privilege Ms Giuffre has been unable to locate such documents Documents concerning any Employment by You from to the present or identified by You in response to Interrogatory No including any records of Your Employment at the Roadhouse Grill in Palm Beach Florida Response to Request No Ms Giuffre objections to this Request on the grounds that it is overly21.1 broad and unduly20.4 burdensome and calls for the production of documents that are irrelevant to this action and not Case Document Filed Page of reasonabl-21.2y20.1 10calculated to lead to the discovery20.1 of admissible evidence Ms Giuffre objects to this request to the extent is seeks documents prote10.2cted the attorney20.7 client work product joint defense public interest-251.1or other applicable privilege Subject to and without waiving the above objections Ms Giuffre 7.2has already20.3 produced documents Bates labelled GIUFFRE01 to GIUFFRE005353 and-250.1will produce non privileged documents responsive to this Request and will continue to supplement this production.-249.6 Documents concerning any allegations of theft by You from the Roadhouse Grill in Palm Beach Florida from Response to Request No Ms Giuffre objects to this request in that it seeks information solel-13.8y to harass embarrass and intimidate Ms Giuffre Ms Giuffre objects to this request to the extent is seeks documents protected the attorney10.3-client privilege the attorney20.2 work product privilege joint defense/common interest privilege public interest privilege 9.6and other applicable privilege Ms Giuffre objects to this request in that it wrongfully17.1 characterizes a theft You Ms Giuffre objects to this request as it seeks documents of sealed juvenile records and the means of obtaining such records are either through court order or illegal means Ms Giuffre has been unable to locate such documents copy of Your federal state or local tax returns for the years to the present whether from the United States or any other country Response to Request No Ms Giuffre objections to this Request on the grounds that it is overly21.1 broad and unduly20 burdensome and calls for the production of doc5.1uments that are irrelevant to this action and not Case Document Filed Page of reasonabl-21.2y20.1 10calculated to lead to the discovery20.1 of admissible evidence Ms Giuffre objects to this request in that it seeks confidential financial information that is irrelevant to this action Ms Giuffre objects to this request in that it seeks financial information from her when she was a minor child starting at age Ms Giuffre objects in that it seeks information protected the attorney20.9-client privilege the attorney20.7 work product privilege joint defense/common interest privilege the accountant client-250.8privilege and 10.3other applicable privilege Subject to and without waiving the above objections Ms Giuffre 7.2has already20.3 produced documents Bates labelled GIUFFRE01 to GIUFFRE005353 and will produce non privileged documents responsive to this Request and will continue to supplement this production Documents concerning Your attendance at or enrollment in any school or educational program of whatever type from to the present Response to Request No Ms Giuffre objections to this Request on the grounds that it is overly21.1 broad and unduly20 burdensome and calls for the production of documents that are irrelevant to this action and not reasonabl-21.2y20.1 9.9calculated to lead to the discovery20.1 of-246.9admissible evidence Ms Giuffre objects to this request to the extent is seeks documents protected by22 the 9.5attorney20.8--6.7client privilege the attorney21.2 work product privilege joint defense/common interest privilege the public interest privilege5.6 and other applicable privilege Ms Giuffre objects to this request in that her school records from when she was a minor child are an invasion of privacy16.8 and sought to harass and embarrass her Subject to and without waiving the above objections Ms Giuffre has already20.2 produced documents Bates labelled GIUFFRE01 to GIUFFRE005353 and will produce non Case Document Filed Page of privileged documents responsive to this Request and will continue to supplement this production diary journal or calendar concerning Your activities between Response to Request No Ms Giuffre objections to this Request on the grounds that the time period is overly17.4 broad and calls for the production of documents that are irrelevant to this action and not reasonabl-21.4y19.9 10.2calculated to to the discovery20.1 of admissible evidence Ms Giuffre objects to this request to the extent it seeks proprietary18.8 and copy20.6right protected materials Ms Giuffre objects in that it seeks information protected the attorney20.4--6.7client privilege the attorne-16.1y work product privilege joint defense/common interest privilege and other applicable privilege Ms Giuffre objects to this request in that it seeks highly19.8 personal and sensitive material from a time when she was being sexually20.8 trafficked Ms Giuffre has been unable to locate such documents Documents relating to Your travel from the period of to the present including but not limited to a copy of Your passport that was valid for any part of that time period any visa issued to You for travel any visa application that You prepared or which was prepared on Your behalf and travel itinerary receipt log or Document including any photograph substantiating Your travel during that time period Response to Request No Ms Giuffre-245.4objections to this Request on the grounds that it is overly17.8 broad and unduly20 burdensome and calls for the production of documents that are irrelevant to this action and not Case Document Filed Page of reasonabl-21.2y20.1 10calculated to lead to the discovery20.1 of admissible evidence Ms Giuffre-246.5objects in that it seeks information protected the attorney20-client privilege the attorney20.6 work product privilege joint defense/common interest privilege and other applicable privilege Ms Giuffre objects to this request in that it is overly20.3 broad and not limited to travel records relevant to the abuse she suffered Ms Giuffre objects to this request in that it seeks information that is wholly20.7 irrelevant to this lawsuit Subject to and without waiving the above objections Ms Giuffre 7.1has already20.2 produced documents Bates labelled GIUFFRE01 to GIUFFRE005353 and will produce non privileged documents responsive to this Request and will continue to supplement this production Per the agreements made in the March meet and confer will attempt to locate and make copies of Plaintiff?s current passport book Documents showing any payments or remuneration of any kind made by Jeffrey Epstein or any of his agents or associates to You from until the present Response to Request-247.2No Ms Giuffre objects to this request in that documents responsive to this request are within the possession custody18.8 and control of the defendant and Jeffrey18.6 Epstein with whom she claims a joint defense privilege and defendant has refused to produce-245.4responsive documents Ms Giuffre objects in that it seeks information protected the attorney20.1--6.9client privilege the attorney20.7 work product privilege joint defense/common interest privilege the public interest privilege and other applicable privilege At this point in time Ms Giuffre has been unable to locate such documents but continues to search for responsive documents Case Document Filed Page of Document reflecting a confidentiality agreement settlement agreement or any contractual agreement of any kind-6.2 between You and Jeffrey Epstein or any attorneys for You and/or Mr Epstein Response to Request No Ms Giuffre objects to this request in that the documents responsive to this request are within the possession custody20.6 and 10.1control of the defendant and Jeffrey20.5 10.1Epstein with whom she claims a joint defense privilege and defendant has refused to produce 9.9responsive documents Ms Giuffre objects in that it seeks information protected attorney20.1-client privilege the attorney19.9 w-8.5ork product privilege,-369.8joint defense/common interest privilege the public interest privilege7.1 and any22 other applicable privilege Giuffre is in possession of a responsive document that contains a confidentiality20.4 provision As discussed during the March meet and confer Defendant obtains and produces Ms Giuffre written waiver from her co-conspirator Mr Epstein of the confidentiality31 provision releasing Ms Giuffre 10from liability21.6 10.1whatsoever under the confidentiality21.4 provision she will produce the document Document reflecting Your intent plan or consideration of asserting or threatening a claim or filing a lawsuit against another Person any Document reflecting such a claim or lawsuit including any complaint or draft complaint or any demand for consideration with respect to any such claim or lawsuit against any Person Response to Request No Ms Giuffre objections to this Request on the grounds that it is overly21 broad and unduly20.3 burdensome and calls for the production of documents that-247.8are irrelevant to this action and not reasonably20.1 calculated to lead to the discovery22.5 of admissible evidence Ms Case Document Filed Page of Giuffre objects to this request to the extent is seeks documents protected the attorney20.3 client work product joint defense or other ap-9.3plicable privilege Ms Giuffre objects because this request is overly broad and unduly19.2 burdensome in that it seeks wholly19 privileged communications from other cases the logging of which on a privilege log would be unduly20.7 burdensome As such Ms Giuffre-245.1is providing categorical privilege entries relating to those matters At this point in time Ms Giuffre has not found any non-privileged documents responsive to this request but continues to search for responsive documents Documents relating to Your driver?s license from Response to Request No Ms Giuffre objections to this Request on the grounds that it is overly21.1 broad and unduly20 burdensome and calls for the production of documents that are irrelevant to this action and not reasonabl-21.7y20.1 10calculated to lead to the discovery20.1 of admissible evidence Ms Giuffre objects to this request in that documents responsive to this request are within the possession custody21.8 and control of the defendant and Jeffrey19.6 Epstein for whom she claims a joint defense privilege and defendant has refused to produce responsive documents At this point in time Ms Giuffre has not found any documents responsive to this request but continues to search for responsive documents copy of Your marriage license from to the present Response to Request No Ms Giuffre objections to this Request on the grounds that it is irrelevant to this action and not reasonably20 calculated to lead to the discovery22.5 of admissible evidence Ms Giuffre Case Document Filed Page of objects in that it-251.6seeks information protected the attorney20.1--6.9client privilege the attorney20.7 work product privilege and other applicable privilege Subject to and without waiving the above objections Ms Giuffre has already20.8 produced documents Bates labelled GIUFFRE01 to GIUFFRE005353 and will produce non privileged documents responsive to this request and will continue to supplement this production documents concerning Your naturalization application to Australia from to the present Response to Re6.1quest No Ms Giuffre objections to this Request on the grounds that it is irrelevant to this action and not reasonably20 calculated to lead to the discovery22.5 of admissible evidence Ms Giuffre objects in that it seeks information protected the attorne-16.1y20.1--7client privilege the attorney20.6 work product privilege and other applicable privilege Ms Giuffre has been unable to locate such documents Documents concerning Your Employment in Australia including but not limited to employment applications pay stubs Documents reflecting Your Income including any tax Documents Response to Request No Ms Giuffre objections to this Request on the grounds that it is overly21.1 broad and unduly20 burdensome and calls for the production of documents that-248.4are irrelevant to this action and not reasonabl-21.2y20.1 10calculated to lead to the discovery20.1 of admissible evidence Ms Giuffre objects to this request in that it seeks confidential financial information Giuffre objects to this request to the extent is seeks-251.1documents protected the attorney19.9 client work product joint defense or Case Document Filed Page of other applicable privilege Ms Giuffre objects to this request in that it seeks overl-20.1y broad financial information not tailored to the sexual abuse and defamation issues in this case Subject to and without waiving the above objections Ms Giuffre has already20.8 produced documents Bates labelled GIUFFRE01 to GIUFFRE005353 and will produce non privileged documents responsive to this request and will continue to supplement this production Documents concerning any massage therapist license obtained by You including any massage therapy license issued in the United States Thailand and/or Australia Response to Request No Ms Giuffre objects to this request in that documents responsive to this request are within the possession custody19.3 and control of the defendant and Jeffrey18.7 Epstein for whom she claims a joint defense privilege and defendant has refused to produce responsive documents Ms Giuffre objects in that it seeks information protected the attorney19.8--7.2client privilege the attorney21.8 work product privilege and other applicable privilege At this point in time Ms Giuffre has not found any non-privileged documents responsive to this request but continues to search for responsive documents Documents concerning any prescription drugs taken by You including the prescribing doctor the dates of said prescription and the dates of any fulfillment of any such prescription Response to Request No Ms Giuffre objections to this Request on the grounds that it is overly21.8 broad and unduly20.3 burdensome and calls for the production of documents that are irrelevant to this action and not reasonably20.1 calculated to lead to the discovery22.5 of admissible evidence Ms Case Document Filed Page of Giuffre objects to this request in that it is not limited in date range in therefore if she was on a prescription drug when she was years old she would have to produce that document Ms Giuffre also objects to this request in that it is not limited to prescription drugs she has taken as a result of the abuse she endured Ms Giuffre objects to this request to the extent it seeks confidential medical records that are not relevant to this action Giuffre objects to this request to the extent is seeks documents protected by the attorney21.8 client work product or other applicable privilege Subject to and without waiving the above objections Ms Giuffre 7.2has already20.4 produced documents Bates labelled GIUFFRE01 to and is producing non-privileged documents responsive to the Request limited to documents relating to prescription drugs relating to her treatment for sexual abuse she suffered-240.6at the hands of the Defendant and Jeffrey19.7 Epstein and relating to conditions or arising after Defendant?s defamatory19.7 statement and will continue to supplement this production Documents written or recorded which reference by name or other description Ghislaine Maxwell Response to Request No Ms Giuffre objects in that it seeks information protected the attorney19.9-client privilege the attorney20.2 work product privilege joint defense/common interest privilege the public interest privilege5.4 and other applicable privilege Ms Giuffre objects to this request extent it seeks proprietary20.1 or copyright protected materials Subject to and without waiving the above objections Ms Giuffre 7.2has already20.3 produced documents Bates labelled GIUFFRE01 to GIUFFRE005353 and will produce non Case Document Filed Page of privileged documents r5.8esponsive to this Request and will continue to supplement her production Documents reflecting notes of or notes prepared for any statements or interviews in which You referenced by name or other description Ghislaine Maxwell Response to Request-247.2No Ms Giuffre objects in that it seeks information protected the attorney20.1-client privilege the attorney21.6 work product privilege joint defense/common interest privilege the public interest privilege6.5 and other applicable privilege Ms Giuffre objects to this request to the extent it seeks proprietary20.3 or copy20.3right protected materials At this point in time Ms Giuffre has not found any non-privileged documents responsive to this request but continues to search for responsive documents Documents concerning any Communications by You or on Your behalf with any media outlet including but not limited to the Daily Mail Daily Express the Mirror National Enquirer New York Daily News Radar Online and the New York Post whether or not such communications were on the record or off the record Response to Request No Ms Giuffre objects in that it seeks information protected the attorney20.1-client privilege the attorney21.8 work product privilege and other applicable privilege Giuffre objects to this request to the extent it seeks proprietary22.3 or copy20.1right protected materials Subject to and without waiving the above objections Ms Giuffre 7.2has already20.4 produced documents Bates labelled GIUFFRE01 to and will Case Document Filed Page of produce non-privileged documents responsive to this Request and will continue to supplement her production Documents concerning any Income received by You from any media outlet in exchange for Your statements whether on the record or off the record regarding Jeffery Epstein Alan Dershowitz Prince Andrew Bill Clinton or Ghislaine Maxwell or any of the individuals identified by You in response to Interrogatory Nos and Response to Request No Ms Giuffre objects in that it seeks information protected the attorney20.1-client privilege the attorney21.8 work product privilege and other applicable privilege Ms Giuffre objects to this request to the extent it seeks proprietary22.3 or copy20.1right protected materials Ms Giuffre objects to this request in that it seeks confidential financial information Subject to and without waiving the above objections Ms Giuffre has already20.4 produced documents Bates labelled GIUFFRE01 to and will produce non-privileged documents responsive to this Request and will continue to supplement her production Documents concerning any actual or potential book television or movie deals concerning Your allegations about being a sex slave including but not limited to a potent8.8ial book by former New York Police Department detective John Connolly and writer James Patterson Case Document Filed Page of Response to Request No Ms Giuffre objects in that it seeks information protected the attorney20.1-client privilege the attorney21.9 work product privilege and other applicable privilege Ms Giuffre objects to this request to the extent it seeks proprietary22.3 or copy20.1right protected materials Ms Giuffre objects to this request in that it seeks confidential financial information Subject to and without waiving the above objections Ms Giuffre has already20.4 produced documents Bates labelled GIUFFRE01 to and will produce non-privileged documents responsive to this Request and will continue to supplement her production manuscripts and/or other writings whether published or unpublished created in whole or in part by or in consultation with You concerning relating or referring to Jeffrey Epstein Ghislaine Maxwell or any of their agents or associates Response to Request No Ms Giuffre objects in that it seeks information protected the attorney20.1-client privilege the attorney21.8 work product privilege and other applicable privilege Ms Giuffre objects to this request to the extent it seeks proprietary22.3 or copy20.1right protected materials Ms Giuffre objects to this request in that it seeks confidential financial information Subject to and without waiving the above objections Ms Giuffre-247.8has already20.4 produced documents Bates labelled GIUFFRE01 to and-249.8will produce non-privileged documents responsive to this Request and will continue to supplement her production Case Document Filed Page of Documents concerning or relating to Victims Refuse Silence the organization referred to in the Complaint including articles of inco6.1rporation any financial records for the organization any Income You have received from the organization and any Documents reflecting Your role within the organization or any acts taken on behalf of the Organization Response to Request No Ms Giuffre objects in that it seeks information protected the attorney20.4-client privilege the attorney20 work product privilege and an-17y other applicable privilege Ms Giuffre objects to this request to the extent it seeks proprietary20.1 or copy20.1right protected mate-5.6rials Ms Giuffre objects to this request in that it seeks confidential financial information Subject to and without waiving the above objections Ms Giuffre 7.2has already20.3 produced documents Bates labelled GIUFFRE01 to GIUFFRE005353 and will produce non privileged documents responsive to this Request and will continue to supplement her production the extent not produced in response to the above list of requested Documents all notes writings photographs and/or audio or video recordings made or recorded by You or of You at any time that refer or relate in any way to Ghislaine Maxwell Response to Request No Ms Giuffre objects to this request in that documents responsive to this request are within the possession custody18.7 and control of the defendant and Jeffrey21.4 Epstein for whom she claims a joint defense privilege and defendant has refused to produce responsive documents Ms Giuffre objects in that it seeks information protected the attorney20.1--6.9client privilege the attorney20.7 work Case Document Filed Page of product privilege and any20 other applicable privilege Ms Giuffre objects to this request to the extent is seeks proprietary and protected material Subject to and without waiving the above objections Ms Giuffre 7.2has already20.3 produced documents Bat-11.3es labelled GIUFFRE01 to GIUFFRE005353 and will produce non privileged documents responsive to this Request and will continue to supplement her production phone records including text messages emails social media Communications letters or any other form of Communication from or to You or associated with You in any way from to the present which concern relate to identify mention or reflect Ghislaine Maxwell Jeffrey Epstein Alan Dershowitz Prince Andrew Bill Clinton or any of the-247.9individuals identified in response to Interrogatory Nos and Response to Request No Ms Giuffre objections to this Request on the grounds that it is overly21.1 broad and unduly20 burdensome and calls for the production of documents that are irrelevant-247.4to this action and not reasonabl-21.2y20.1 10calculated to lead to the discovery20.1 of admissible evidence Ms Giuffre objects to this request to the extent it seeks documents from any19.3one associated with as that is vague and ambiguous Ms Giuffre objects to this request in that documents responsive to this request are within the possession custody19.3 and control of the defendant and Jeffrey18.7 Epstein for whom she claims a joint defense privilege and defendant has refused to produce responsive documents Ms Giuffre objects in that it seeks information protected by21 the attorney20.5-client privilege the attorney20.3 work product privilege the public interest privilege,-259.2and other applicable privilege Case Document Filed Page of Ms Giuffre objects to this request to the extent is seeks proprietar-16.7y20.1 and copy20.2right protected material Subject to and without waiving the above objections Ms Giuffre 7.2has already20.3 produced documents Bates labelled GIUFFRE01 to GIUFFRE005353 and will produce non privileged documents responsive to this Request and will continue to supplement her production While Ms Giuffre has produced her documents Ms Giuffre?s response does not include documents from any21.3one associated with based on the above referenced objection Documents relating to massages including but not limited to any Documents reflecting the recruiting or hiring of masseuses advertising for masseuses flyers created for distribution at high schools or colleges and records reflecting or calls to Persons relating to massages Response to Request No Ms Giuffre objections to this Request on the grounds that it is overly21.1 broad and unduly20 burdensome and calls for the production of documents that are irrelevant to this action and not reasonabl-21.2y20.1 10calculated to lead to the discovery20.1 of-246.9admissible evidence Ms Giuffre objects to this request in that it is not time limited in Ms Giuffre objects to this request in that documents responsive to this request are within the possession custody21 and control of the defendant and Jeffre-16.2y20 Epstein for whom she claims a joint defense privilege and defendant has refused to produce responsive documents Ms Giuffre objects in that it seeks information protected the attorney10-client privilege the attorney20.9 work product privilege public interest privilege5.3 and other applicable privilege Ms Giuffre has been unable to locate such documents Case Document Filed Page of 37.-1750Statements or records from any bank into which You deposited money received from Jeffrey Epstein any Person identified in Interrogatory No any witness disclosed in Your Rule a disclosures any media organization or any employee or affiliate of any media organization Response to Request No Ms Giuffre objects in that it seeks information protected the attorney19.9-client privilege the attorney20.2 work product privilege joint defense/common interest privilege the public interest privilege5.2 and other applicable privilege Ms Giuffre objects to this request in that it seeks personal financial information Ms Giuffre objects-246.9to this request in that it is overly19.8 broad as it has no time limitation Subject to and without waiving the above objections Ms Giuffre 7.2has already20.3 produced documents Bates labelled GIUFFRE01 to GIUFFRE005353 and will produce non privileged documents responsive to this Request and will continue to supplement her production Dated April Respectfully21.1 Submitted BOIES SCHILLER FLEXNER Sigrid McCawley Sigrid McCawley20.7 Pro Hac Vice Meredith Schultz Pro Hac-243.8Vice Boies Schiller Flexner LLP Las Olas Blvd Suite Ft Lauderdale FL David Boies Boies Schiller Flexner LLP Main Street Armonk NY Case Document Filed Page of CERTIFICATE OF SERVICE 9.5certify21.3 that on April served Plaintiff Virginia Giuffre?s Second Amended Supplemental Responses and Objections to Defendant?s First Set of Discovery Requests on the following Laura A Menninger Esq Jeffrey20.6 Pagliuca Esq HADDON MORGAN FOREMAN P.C East th Avenue Denver Colorado Tel Fax Email lmenninger hmflaw.com jpagliuca hmflaw.com Sigrid McCawley20.5_ Sigrid McCawley20.4 Case Document Filed Page of
