Giuffre_Maxwell_Batch5_p00028.png
Extracted Text (OCR)
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 14 of 40
Response to Interrogatory No. 8
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.
Additionally, Ms. Giuffre objects to this interrogatory because naming some such individuals
would jeopardize her physical safety based on credible threats to the same. Ms. Giuffre refers to
the list of witnesses identified in her Revised Rule 26 Disclosures.
9. Identify any Employment You have had from 1996 until the present, including
without limitation, the name of Your employer or the name of any Person who engaged You for
such Employment, the address and telephone number for any such Employment, the beginning
and ending dates of any such Employment, Your job title in such Employment, and Your
Income from such Employment.
Response to Interrogatory No. 9
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 objects to this request in that it is overly broad and unduly burdensome, and seeks
information that is not relevant to this case.
10. Identify any Income from any source other than Your Employment that You have
received from January 1, 1996 until the present, including the Person or entity providing such
Income, the amount of the Income, the dates on which any such Income was received, and
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Dates
Document Details
| Filename | Giuffre_Maxwell_Batch5_p00028.png |
| File Size | 272.7 KB |
| OCR Confidence | 95.4% |
| Has Readable Text | Yes |
| Text Length | 1,944 characters |
| Indexed | 2026-02-04 12:43:49.285201 |