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Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 28 of 40 (emphasis supplied). Plaintiff denied only “a part of a matter” and therefore was required to “specify the part admitted.” In Request for Admissions Nos. 1-8 and 13, Plaintiff failed to specify any part that was admitted. Her answers violate Rule 36. Request for Admission No. 12. Admit that You never had a conversation with Bill Clinton regarding him flying with Ghislaine Maxwell in a helicopter. Response: Objection. Defendant Maxwell has clearly incorrectly interposed and comingled the facts which comprise the foundation of this request for admission. Ms. Giuffre has never alleged that she “had a conversation with Bill Clinton regarding him flying with Ghislaine Maxwell in a helicopter.” Instead, Ms. Giuffre has alleged, “I flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill [Clinton] in a huge black helicopter that Jeffrey had bought her.” Sara Nathan, Bill Clinton Pictured with Jeffrey Epstein’s Social Fixer, Daily Mail, (12 January 2015). As a threshold matter, a court must determine whether the statements set forth in a request for admissions satisfy the formal requirements of Rule 36 .... Consequently, Ms. Giuffre objects to answering this request for admission as it is based on “half-truths,” which make it impossible to answer without a qualified response. Plaintiff objected to this request for admission and provided no answer. That is improper. The request required Plaintiff to admit whether she had a conversation with President Clinton regarding him flying in a helicopter with Ms. Maxwell. Either she is able to admit this request in full or in part, or she is able to deny the request in full or in part, as Rule 36 requires. She may not object and refuse to admit or deny. Ill. Plaintiff’s responses to requests for production are deficient. RFP No. 1. All Communications and Documents identified in Interrogatories 5- 14, above. Response: Ms. Giuffre objects in that it seeks information protected by the attorney- client/work product privilege, and any other applicable privilege stated in the General Objections. Ms. Giuffre objects to this request on the grounds that it is 25