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Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 17 of 20 22. Identify all flights you have taken on aircraft on which Ms. Giuffre was also a passenger. 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: As she testified during her deposition, Ms. Maxwell has no recollection of ever having been on a flight on which Ms. Giuffre was a passenger. Ms. Maxwell does not possess any other records which might refresh her recollection with respect to any such flights. 23. Identify all occasions on which you either observed Ms. Giuffre massaging Jeffrey Epstein or understood that she was massaging 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: Ms. Maxwell, as she has already testified, has no specific recollection of ever seeing Plaintiff massage Mr. Epstein or having any understanding that Plaintiff was massaging Mr. Epstein on any specific occasion, nor does she possess any records which would permit her to identify any such occasion. 15