Giuffre_Maxwell_Batch2_p00316.png

Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 8 of 20 6. Identify all loans issued to you by Jeffrey Epstein, directly or indirectly or through any entity or person affiliated with or controlled by Epstein, from 1992 through the present, detailing the amount of the loans, the terms of the loans, the interest rate of the loans, and any payments made by you or on your behalf to repay such loans. ANSWER: Ms. Maxwell objects to this Interrogatory on the grounds that it is overly broad and unduly burdensome and calls for information that is irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Maxwell objects to this Interrogatory 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. This Interrogatory also violates Local Rule 33.3(a) — (c) in that it does not seek the name of witnesses or the custodian and location of documents. Finally, Ms. Maxwell objects to this Interrogatory to the extent it seeks information from a time period not relevant to this action. Without waiver of the foregoing, Ms. Maxwell responds as follows: From the time period of January 1, 2015 through the present, Ms. Maxwell has had no loans issued to her by Jeffrey Epstein, either directly, indirectly or by any entity or person affiliated with or controlled by him. 7. Identify any other employment you have held since 1999, how you were compensated, and how much you were compensated, broken down by job title, employer, and year. ANSWER: Ms. Maxwell objects to this Interrogatory on the grounds that it is overly broad and unduly burdensome and calls for information that is irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Maxwell objects to this Interrogatory 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. This Interrogatory also violates Local Rule 33.3(a) — (c) in that it does not seek the name of witnesses or the custodian and location of documents. Finally, Ms. Maxwell objects to this Interrogatory to the extent it seeks information from a time period not relevant to this action. Without waiver of the foregoing, Ms. Maxwell responds as follows: From January 1, 2015 to the present, Ms. Maxwell has not been employed as that term is commonly understood to mean a salaried position.