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Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 18 of 20 24, Identify all persons or other sources of information who have told you or that suggested that Epstein had sexual interactions with persons under the age of 18. 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 absence of definition of “sexual interactions.” 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. Ms. Maxwell objects to this Interrogatory to the extent it calls for information protected by the attorney/client, attorney work product and joint defense privileges. 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 knows of no person who has communicated to her directly any information concerning sexual interactions between Mr. Epstein and a person under the age of 18. 25. Identify all girls under the age of 18 with whom you have interacted at one of Epstein’s properties, including his Palm Beach mansion or his New York City mansion. 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 described during her deposition, the only females with whom Ms. Maxwell interacted at any of Epstein’s properties knowing that they were under the age of 18 were either members of her own extended family or the minor children of her or Mr. Epstein’s friends, and any such interactions did not involve anything sexual or inappropriate by herself or anyone else to Ms. Maxwell’s knowledge. Based on their own privacy rights, Ms. Maxwell is not identifying these family members or children of her or Mr. Epstein’s friends. 16