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Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 4 of 20 10. The Interrogatories seek information that is confidential and implicates Ms. Maxwell’s privacy interests. To the extent such information is relevant and discoverable in this action, M s. Maxwell will produce such materials subject to an appropriate protective order pursuant to Fed. R. Civ. P. 26(c) limiting their dissemination to the attorneys and their employees. OBJECTIONS TO DEFINITIONS 1. Ms. Maxwell objects to Definition No. 1 regarding “Agent” because it is an incorrect statement of the law. 2. Ms. Maxwell objects to the Definition of “communication” to the extent it expands upon the meaning ascribed to that term by Local Rule 26.3(c). 3. Ms. Maxwell objects to Definition No. 3 regarding “Defendant.” The Definition is overly broad and unduly burdensome to the extent it attempts to extend the scope of the Interrogatories to information in the possession, custody or control of individuals other than Ms. Maxwell or her counsel. 4. Ms. Maxwell objects to the Definition No. 4 regarding “Document” to the extent it expands upon the meaning ascribed to that term by Local Rule 26.3(c). 5. Ms. Maxwell objects to Definition No. 5 regarding “Employee.” Ms. Maxwell is an individual, sued in an individual capacity, and therefore there is no “past or present officer, director, agent or servant” of hers. Additionally, “attorneys” and “paralegals” are not “employees” of Ms. Maxwell given that she herself is not an attorney and therefore cannot “employ” attorneys. 6. Ms. Maxwell objects to Definition No. 7 of “Jeffrey Epstein” to include not only entities but also any employee, agent, attorney, consultant or representative of him, to include any entities owned or controlled by him. Questions related to an individual named Jeffrey Epstein have been construed to mean only that individual and not any other individual who is affiliated in some capacity with entities owned or controlled by him. 7. Ms. Maxwell objects to Definition No. 8 regarding “Massage” to include “any person touching another person,” as the touching of another person may or may not include what is commonly understood to mean massage, it may be for a harmful, offensive or accidental reasons, or for any other purposes, or may be a touching incidental to being in close proximity with another. Similarly, a definition of “massage” to include “using any object...to touch another person” can mean a wide variety of activities and for various purposes that exceed the relevancy of this defamation action. 8. Ms. Maxwell objects to Definition No. 9 regarding “Person” to the extent it expands upon the meaning ascribed to that term by Local Rule 26.3(c). 9. Ms. Maxwell objects to Definition No. 11 regarding “You” or “Your.” The Definition is overly broad and unduly burdensome to the extent it attempts to extend the scope of