Giuffre_Maxwell_Batch4_p00065.png

Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 21 of 40 By way of example only, Plaintiff's mother, father, boyfriend, and ex-fiance all have testified that in 1998 and 1999, |i OO e—CSCSCCés et Further, Plaintiff has claimed as losses “medical expenses of ‘not less than’ $100,000,” yet her interrogatory response states simply that she “is not certain as to her the sum of her medical expenses from 1999 to the present, and therefore is unable to answer that subpart. Ms. Giuffre is not aware of what health insurance carrier or other organization paid for her historical medical expenses.” This is non-responsive. It is insufficient to claim that one is “not certain” of the answers as to medical expenses when she is seeking ‘not less than’ $100,000 in damages from that category. Interrogatory No. 14. Identify any Person who You believe subjected You to, or with whom You engaged in, any illegal or inappropriate sexual contact, conduct or assault prior to June 1999, including the names of the individuals involved, the dates of any such illegal or inappropriate sexual contact, conduct or assault, whether Income was received by You or anyone else concerning such event, whether a police report was ever filed concerning such event and the outcome of any such case, as well as the address and location of any such event. Response: Ms. Giuffre objects to this request in that it is overbroad and invades Ms. Giuffre right to privacy (including her constitutionally-protected right of privacy) by seeking confidential information relating to the sexual abuse of a minor sex abuse victim. Ms. Giuffre objects to this request in that it seeks sexual assault information for a period prior to the sexual abuse at issue in this matter, and for a period when she was a minor child. The Court has excluded the production of medical records from prior to 1999, stating, “the damage issue relates, in my view, solely to the defamation.” (April 21, 2016, Hearing Transcript at 20:23-24). This holding applies equally to pre-1999 sexual assault... Additionally, it has become increasingly clear that Defendant’s counsel is seeking these documents for the improper purpose of harassment .... Ms. Giuffre also objects to this request because such events would have taken place in Florida, and information relating to those events is protected from 18