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Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 26 of 48 m. Jeffrey Epstein; Ghislaine Maxwell Any witness disclosed in Plaintiff’s Rule 26(a) disclosures; Any witness identified by You in response to Interrogatory No. 8 and No. 14; Sky Roberts; Lynn Roberts; Kimberley Roberts; Daniel LNU, half-brother of Plaintiff; Carol Roberts Kess; Philip Guderyon; Anthony Valladares; Anthony Figueroa; Ron Eppinger Response to Request No. 5 Ms. Giuffre objection to this request on the grounds that it is overly broad and unduly burdensome, particularly as it seeks documents relating to over 60 individuals, 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. Giuffre objects because compliance with this request is unduly burdensome. Ms. Giuffre objects to this request in that documents responsive to this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms. Giuffre’s request seeking communications between the Defendant and Ms. 25