Giuffre_Maxwell_Batch4_p00106.png

Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 22 of 45 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) objects in that it seeks information protected by the attorney-client/work product privilege, and any other applicable privilege stated in the General Objections. Additionally, to the extent that it is available to Ms. Giuffre, all of this information is already in the possession of Maxwell as she obtained and produced police reports regarding Ms. Giuffre, which Ms. Giuffre did not have in her possession. Ms. Giuffre was also questioned for seven hours in her May 3, 2016, deposition by Defendant’s attorney. Finally, where a party possesses records and documents obtained or generated illegally, the court has the equitable power to vindicate and protect the rights of the parties affected. Socialist Workers Party v. Attorney Gen. of U.S., 666 F. Supp. 621, 623 (S.D.N.Y. 1987). For all of the foregoing reasons, Ms. Giuffre objects to this request. 21