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Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 4 of 45 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) Case no. 08-80736 CIV-Marra, pending in the Southern District of Florida; Bradley Edwards and Paul Cassell v. Alan Dershowitz, Case no. CACE 15-000072, from the Seventeenth Judicial Circuit, Broward County, Florida; and Jane Doe No. 102 v. Jeffrey Epstein, Case No. 09-80656- CIV-Marra/Johnson (Southern District of Florida). Accordingly, due to the undue burden of individually logging responsive privileged documents related to Defendant’s overly broad requests, Plaintiff has employed categorical logging of such privileged responsive documents pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a minor victim of sexual trafficking. Ms. Giuffre objects to the requests to the extent they are overly broad and unduly burdensome. Ms. Giuffre’s responses to Defendant’s Second Set of Discovery Requests as being made after reasonable inquiry into the relevant facts, and are based only upon the information and documentation that is presently known to her. Ms. Giuffre reserves the right to modify and/or supplement her responses. Ms. Giuffre has produced documents and information in response to these Requests. Ms. Giuffre incorporates her above-listed general objections in the responses herein. INTERROGATORIES 5. Identify each Communication that You or Your Attorneys have had with any author, reporter, correspondent, columnist, writer, commentator, investigative journalist, photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any media organization or independent consultant to the same, including: a. the date of any such Communication;