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Giuffre_Maxwell_Batch1_p00764.png

Source: GIUFFRE_MAXWELL  •  Size: 260.5 KB  •  OCR Confidence: 94.5%
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Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 12 of 48 b. — the form of any such Communication, whether oral or written and if written, the format of any such Communication; c. the identities of all persons involved in the Communication, including the identity of the law enforcement agency with whom the agent is or was affiliated; d. the case number associated with any such Communication; e. the subject matter of any such Communication; f. the disposition of any case associated with any such Communication, irrespective of whether the matter was sealed, expunged or later dismissed. Response to Interrogatory No. 4 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects to this interrogatory in that it seeks protected information regarding confidential investigations. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre objects to the extent this seeks information regarding sexual assaults that occurred prior to her involvement with the Defendant and Jeffrey Epstein. Ms. Giuffre responds as follows: Ms. Giuffre, in accordance with the Court’s direction at the hearing on April 21, 2016, has submitted documents to the Court for In Camera review. Ms. Giuffre met with the FBI on or about March 17, 2011. Ms. Giuffre also corresponded with Maria Villafano from the U.S. Attorney’s office and that correspondence has been produced. 5. Identify each Communication that You or Your Attorneys have had with any author, reporter, correspondent, columnist, writer, commentator, investigative journalist, 11

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Document Details

Filename Giuffre_Maxwell_Batch1_p00764.png
File Size 260.5 KB
OCR Confidence 94.5%
Has Readable Text Yes
Text Length 1,775 characters
Indexed 2026-02-04 12:35:37.848834