Giuffre_Maxwell_Batch1_p00424.png

Case 1:15-cv-07433-LAP Document 1320-17 Filed 01/03/24 Page 2 of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ween eee eee eee eee enn eneneenenenne xX VIRGINIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. ween eee eee ene een en ene eneneenene xX DEFENDANT GHISLAINE MAXWELL’S RESPONSES AND OBJECTIONS TO PLAINTIFF’S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS Defendant Ghislaine Maxwell, by and through her undersigned counsel, hereby responds to Plaintiff's Second Request for Production of Documents (the “Requests”). PRELIMINARY STATEMENT AND GENERAL OBJECTIONS 1. This response is made to the best of Ms. Maxwell’s present knowledge, information and belief. Ms. Maxwell, through her attorneys of record, have not completed the investigation of the facts relating to this case, have not completed discovery in this action, and have not completed preparation for trial. Ms. Maxwell’s responses to Plaintiffs requests are based on information currently known to her and are given without waiving Ms. Maxwell’s right to use evidence of any subsequently discovered or identified facts, documents or communications. Ms. Maxwell reserves the right to supplement this Response in accordance with Fed. R. Civ. P. 26(e). 2. Ms. Maxwell objects to the Requests to the extent they attempt to impose any requirement or discovery obligation greater than or different from those under the Federal Rules of Civil Procedure, the local rules of this Court or any Orders of the Court. 3. Ms. Maxwell objects to the Requests to the extent they seek documents or information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the Federal Rules of Evidence, any common interest privilege, joint defense agreement or any other applicable privilege. 4. Ms. Maxwell objects to the Requests to the extent they seek documents or information outside of Ms. Maxwell’s possession, custody or control.