Giuffre_Maxwell_Batch2_p00318.png

Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 10 of 20 As she testified at her deposition, Ms. Maxwell has contacted a number of professional masseuses from spas in various locations, including New York, Palm Beach, and the U.S. Virgin Islands, to provide professional, adult massages to be given to Jeffrey Epstein. Ms. Maxwell relied on and expected those various high-end registered and licensed spas to hire professional accredited massage therapists and to check the credentials, including the age and professional qualifications, of their employees. 10. Have you ever recruited, found, hired, approached, introduced, procured, or otherwise obtained, for the purposes of Jeffrey Epstein employing, any female who was not at the time a certified or licensed massage therapist for the purpose of having that female perform a massage on Jeffrey Epstein. If yes, please identify the name of each such female, the last known address and phone number, and a description of the circumstances surrounding that female meeting with your (sic) or 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. 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: Not to her knowledge. 11. Have you ever recruited, found, hired, introduced, approached, or encouraged any female, and told that female to meet with, or show themselves to, Jeffrey Epstein because he was associated in some way with Victoria’s Secret. For each such female, please list her name, address, telephone number, as well as a description of the circumstances surrounding that female’s encounter with your or 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 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