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Case 1:15-cv-07433-LAP Document 1320-17 Filed 01/03/24 Page 9 of 25 DOCUMENT REQUEST NO. 9 Produce any Joint Defense Agreement entered into between You and Alan Dershowitz from 1999 to the present. RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or information protected by the attorney/client privilege, the work-product doctrine, the common interest privilege or any other applicable privilege. Subject to and without waiver of the foregoing, Defendant has been unable to locate any documents responsive to this Request. DOCUMENT REQUEST NO. 10 Produce any documents concerning any Joint Defense Agreement entered into between You and Alan Dershowitz from 1999 to the present. RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or information protected by the attorney/client privilege, the work-product doctrine, the common interest privilege or any other applicable privilege. Subject to and without waiver of the foregoing, Defendant has been unable to locate any documents responsive to this Request. DOCUMENT REQUEST NO. 11 Produce any documents concerning any of Your attorneys’ or agents’ communications with Alan Dershowitz’s attorneys or agents from 1999 to the present RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or information protected by the attorney/client privilege, the work-product doctrine, the common interest privilege or any other applicable privilege. Defendant is withholding communications between Mr. Dershowitz’s counsel and Defendant’s counsel which contain work product and concern joint defense or common interest matters. DOCUMENT REQUEST NO. 12 Produce all documents concerning Virginia Giuffre (a/k/a Virginia Roberts), whether or not they reference her by name. This request includes, but is not limited to, all communications, diaries, journals, calendars, blog posts (whether published or not), notes (handwritten or not), memoranda, mobile phone agreements, wire transfer receipts, or any other document that concerns Plaintiff in any way, whether or not they reference her by name. RESPONSE: Ms. Maxwell objects to this Request as overly broad, unduly burdensome and interposed for improper purposes. Response to this Request would literally entail defense counsel reviewing for privilege every single document in their possession related to this case. Ms. Maxwell further objects to this Request on the grounds that it is cumulative and duplicative. Ms. Maxwell further objects to this request as exceeding the scope of this Court’s March 17, 2016 Order. Ms. Maxwell also objects to this Request to the extent it calls for information relating to Virginia Roberts Giuffre that exists within the public domain, the internet