Giuffre_Maxwell_Batch1_p00442.png

Case 1:15-cv-07433-LAP Document 1320-17 Filed 01/03/24 Page 20 of 25 annoying or harassing Ms. Maxwell. Ms. Maxwell’s personal financial information is not at issue in this matter and information relating thereto is irrelevant. Ms. Maxwell intends to move for a Protective Order regarding her personal financial information and is refusing to respond and is withholding documents under the category of “Document Requests Concerning Punitive Damages” until the motion is resolved. Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this Request in abeyance pending either a finding of liability or resolution of dispositive motions. Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will Defendant move for a Protective Order with regard to this Request, without further conferral. DOCUMENT REQUEST NO. 36 Produce all title certificates, registration certificates, bills of sale, and other evidences of ownership possessed by You or held for Your beneficial interest with respect to any of the following described property owned by You or held directly or indirectly for Your beneficial interest from January 2015 to the present: a. Motor vehicles of any type, including trucks, other automobiles, and two or three-wheeled vehicles (motorcycles, ATV, etc.). b. Aircraft of any type, including jets, propeller planes, and helicopters c. Boats, launches, cruisers, sailboats, or other vessels of any type d. Real estate and real property RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Maxwell objects to this Request on the grounds that it is propounded for the improper purpose of annoying or harassing Ms. Maxwell. Ms. Maxwell’s personal financial information is not at issue in this matter and information relating thereto is irrelevant. Ms. Maxwell intends to move for a Protective Order regarding her personal financial information and is refusing to respond and is withholding documents under the category of “Document Requests Concerning Punitive Damages” until the motion is resolved. Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this Request in abeyance pending either a finding of liability or resolution of dispositive motions. Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will Defendant move for a Protective Order with regard to this Request, without further conferral. DOCUMENT REQUEST NO. 37 From January 2012 to the present, produce all documents concerning any source of funding for the TarraMar Project or any other not-for-profit entities with which You are 19