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Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 11 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
8. Identify the individuals referenced in Your pleadings filed in the U.S. District
Court for the Southern District of Florida, Jane Doe I and Jane Doe 2 v. United States of
America, 08-cv-80736-KAM, as the “high-profile non-party individuals” to whom Mr. Jeffrey
Epstein sexually trafficked You, “including numerous prominent American politicians, powerful
business executives, foreign presidents, a well-known Prime Minister, and other world leaders,”
including as to each episode of alleged sexual trafficking:
a. the date of any such sexual trafficking;
b. the location of any such sexual trafficking;
c. any witnesses to any such sexual trafficking;
d. any Income You received in exchange for such sexual trafficking; and
e. any Documents You have to support or corroborate Your claim of such sexual
trafficking.
Response to Interrogatory No. 8:
Ms. Giuffre objects to this interrogatory in that it violates Rule 33 as its subparts, in
combination with the other interrogatories, exceed the allowable twenty-five interrogatories. Ms.
Giuffre also 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 refers to the list of witnesses identified in her Revised Rule 26 Disclosures.
Also, notwithstanding previously-noted objections, Ms. Giuffre testified in Edwards v. Cassell,
Broward County Case Number CACE 15-000072 on January 16, 2016, regarding the subject
matter requested. See GIUFFRE005094- GIUFFRE007566. Ms. Giuffre additionally testified
regarding the subject matter requested in this interrogatory on in the above-captioned case in her
deposition on May 3, 2016. Additionally, Ms. Giuffre was trafficked to other individuals whose
name she never learned or whose names she does not remember. Identification of any other
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Document Details
| Filename | Giuffre_Maxwell_Batch4_p00095.png |
| File Size | 305.8 KB |
| OCR Confidence | 95.2% |
| Has Readable Text | Yes |
| Text Length | 2,012 characters |
| Indexed | 2026-02-04 12:40:51.265837 |