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Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 18 of 45 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) Response to Interrogatory No. 14: 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 for two reasons. First, sexual assault is not only a crime, but a physical injury, and an injury for which medical treatment is needed and for which a forensic medical exam is often performed. Accordingly, any documentation of sexual assault is necessarily akin to a medical record, and therefore precluded under the Court’s April 21, 2016 Order. Furthermore, this Court’s holding likely expands specifically to sexual abuse and assault prior to 1999, because the holding was in response to the following argument from Ms. Menninger: “She has also alleged, for example, that many, several, three, I think, at last count, or four individuals had sexually abused her prior to ever meeting Mr. Epstein.” (April 21, 2016, Hearing Transcript at 11:24-12:2). Additionally, it has become increasingly clear that Defendant’s counsel is seeking these documents for the improper purpose of harassment as part of Defendant’s counsel’s campaign to blame the victim and make Ms. Giuffre (who was 15 years old or younger at the time of the requested documents). Maxwell’s counsel has used offensive language in this proceeding at every turn. First, Ms. Menninger called Ms. Giuffre a “professional victim” in open court. (January 14, 2016 Hearing Transcript at 5:9). Then, Mr. Pagliuca stated that Ms. Giuffre “cried 17