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Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 6 of 48 Ms. Giuffre incorporates her above-listed general objections in the responses herein. INTERROGATORIES 1. State: a. Your present residential address; b. Each residential address You have had since 1998, including any residential treatment facilities; c. the dates You lived at each address; d. — the other Persons who lived with You at each address and for what period of time they lived at such address. Response to Interrogatory One: Ms. Giuffre objects to this interrogatory in part because it violates Rule 33.3. Ms. Giuffre objects to this interrogatory in that it seeks information that is sought by Defendant only to harass and intimidate Ms. Giuffre who was a victim of sexual trafficking. Per the Plaintiff’s First Responses and Objections, and per our representations during the March 21, 2016 meet and confer phone call, we are working diligently 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. Additionally, per the March 21, 2016 meet and confer phone call, we are addressing with the Plaintiff whether she will reveal here address to Defendant’s counsel confidentially and we will update you with her response. a. Due to safety concerns with respect to Ms. Giuffre and her minor children, she is not at liberty to reveal her present residential location. To ensure that Defendant is not prejudiced by the failure to provide information about Ms.