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Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 12 of 40 6. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as You contend in paragraph 9 of Count | of Your Complaint, including: a. b. the exact false statement; the date of its publication; the publishing entity and title of any publication containing the purportedly false statement; the URL or internet address for any internet version of such publication; and the nature of the publication, whether in print, internet, broadcast or some other form of media. Response to Interrogatory No. 6 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the agency privilege, investigative privilege, spousal privilege, accountant client privilege, and any other applicable privilege. Ms. Giuffre further objects because the information requested above is in the possession of Defendant who has failed to comply with her production obligations in this matter. 7. State whether You believe that You have ever been defamed by anyone other than Ghislaine Maxwell. If so, as to each alleged act of Defamation, state a. b. the exact false statement; the date of its publication; 11