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Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 2 of 40 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF’S RESPONSE AND OBJECTIONS TO DEFENDANT’S FIRST SET OF DISCOVERY REQUESTS TO PLAINTIFF Plaintiff hereby serves her responses and objections to Defendant’s First Set of Discovery Requests. GENERAL OBJECTIONS Defendant’s First Set of Discovery Requests violates Local Civil Rule 33.3. Defendant has served interrogatories that are in direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation of each category of damage alleged, and the existence, custodian, location and general description of relevant documents, including pertinent insurance agreements, and other physical evidence, or information of a similar nature.” Local Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil Rule 33.3, and therefore, they should not be served because they are not “a more practical method of obtaining the information sought than a request for production or a deposition,” and because they were served in advance of the period “30 days prior to the discovery cut-off date.” Local Civil Rule 33.3(b), (c). The interrogatories you served violate Local Rule 33.3 and we ask