Giuffre_Maxwell_Batch4_p00118.png

Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 34 of 45 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE007566, and will produce non- privileged documents responsive to this Request and will continue to supplement her production limited to documents that do not depict images of her minor children. Ms. Giuffre does not have “original, native format,” as requested so she is producing the paper copies she has in her possession, custody and control. Furthermore, Ms. Giuffre has now produced the pictures in her possession related to the above-referenced case. Any remaining photographs not produced are solely in the possession of the Defendant and her co-conspirators. 6. All Documents concerning any Communications between you or your attorneys and any witness or any potential witness in Giuffre v. Maxwell. Response to Request For Production No. 6: Ms. Giuffre objects to this request on the grounds that it is overly broad and unduly burdensome, particularly as it seeks documents relating to hundreds of individuals, and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Giuffre objects because compliance with this request is unduly burdensome. Ms. Giuffre objects to this request in that documents responsive to this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege, and defendant has refused to produce responsive documents to Ms. Giuffre’s request seeking communications between the Defendant and Ms. Giuffre and between Jeffrey Epstein and Ms. Giuffre. Ms. Giuffre further objects to this request to the extent is seeks documents protected by the attorney client, work product, joint defense, public interest or any other applicable privilege. 33