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Case 18-2868, Document 278, 08/09/2019, 2628230, Page79 of 648 Jane Doe No. 102 v. Jeffrey Epstein, Case No. 09-80656-CIV-Marra/Johnson (Southern District of Florida). Accordingly, due to the undue burden of individually logging responsive, privileged documents related to Defendant’s overly-broad requests, Plaintiff has employed categorical logging of such privileged responsive documents pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a minor victim of sexual trafficking. Ms. Giuffre objects to the requests to the extent they are overly broad and unduly burdensome. Ms. Giuffre’s responses to Defendant's Second Set of Discovery Requests are being made after reasonable inquiry into the relevant facts, and are based only upon the information and documentation that is presently known to her. Ms. Giuffre reserves the right to modify and/or supplement her responses. Ms. Giuffre has produced documents and information in response to these Requests. Ms. Giuffre incorporates her above-listed general objections in the responses herein. SUPPLEMENTAL INTEROGATORY RESPONSES 6. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as You contend in paragraph 9 of Court 1 of Your Complaint, including: a. the exact false statement; b. the date of its publication; c. the publishing entity and title of any publication containing the purportedly false statement; d. the URL or internet address for any internet version of such publication; and e. the nature of the publication, whether in print, internet, broadcast or some other form of media.