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Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 9 of 20 8. Identify all persons who gave a massage to Jeffrey Epstein with whom you had any involvement, either in meeting the person who gave a massage, finding the person who gave the massage, making a referral to the person who gave the massage, conversing with the person who gave the massage, staffing the person who gave the massage, or otherwise facilitating that person giving a massage to Jeffrey Epstein. 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 the Interrogatory as vague and ambiguous given the definition of “massage” to include any person touching another person. Ms. Maxwell objects to this Interrogatory on the grounds that it is propounded for the improper purpose of annoying or harassing Ms. Maxwell. 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: As she testified at her deposition, Ms. Maxwell on occasion met with adult, professional women and men who were employed at high-end spas or resorts and asked whether they made home visits for the purposes of massages. She does not recall the names of those persons who ended up making professional, adult home visit massages that occurred between the years 2000 and 2002. Other deposition testimony in this case has included that of Johanna Sjoberg who stated that she had met with Ms. Maxwell and later had trained for and become a masseuse and provided professional massages to Mr. Epstein. 9. Identify all efforts undertaken by you to ascertain the age and professional qualifications of any individual in your answer to Interrogatory number 9. 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 the Interrogatory as vague and ambiguous given the definition of “massage” to include any person touching another person. Ms. Maxwell objects to this Interrogatory on the grounds that it is propounded for the improper purpose of annoying or harassing Ms. Maxwell. Further, Ms. Maxwell objects to this Interrogatory as a violation of Local Rule 33.3(a) — (b) as it seeks neither the names of witnesses nor the locations of documents and is more appropriately discovered through the deposition of Ms. Maxwell, during which time she already answered questions on this topic. 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: