Giuffre_Maxwell_Batch2_p00324.png

Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 16 of 20 20. Identify all reasons why you failed to appear for a deposition scheduled in about 2009 to 2010 in a sexual assault civil suit filed against 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 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: Ms. Maxwell did not fail to appear for a scheduled deposition in 2009 or 2010. At the only scheduled deposition date, December 9, 2009, Mr. Edwards failed to appear and failed to communicate with Ms. Maxwell’s counsel following the November 9, 2009 involuntary bankruptcy of his law firm occasioned by the arrest (and subsequent imprisonment) of his law partner. Thereafter, including during 2010, the parties never agreed to a particular deposition date. 21. Identify all communications you have had with Jeffrey Epstein since January 1, 2015, and the substance of those communications. 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 documents and is more appropriately discovered through the deposition of Ms. Maxwell, during which time she already answered questions on this topic. The Court has limited discovery of communications between 2002 to the present with Mr. Epstein to those related to the sexual trafficking of women. 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: Ms. Maxwell already produced any written communications with Mr. Epstein that were responsive to the Interrogatory for the same, as limited by the Court to (a) all communications from January 2015 and (b) all documents related to sex trafficking. 14