Giuffre_Maxwell_Batch5_p00034.png

Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 20 of 40 attorney client, work product, joint defense and other applicable privileges. Ms. Giuffre is withholding documents based on this objection. 5. All Documents relating to any Communications occurring from 1998 to the present with any of the following individuals or with their attorneys, agents or representatives: a. b. m. Jeffrey Epstein; Ghislaine Maxwell Any witness disclosed in Plaintiff's Rule 26(a) disclosures; Any witness identified by You in response to Interrogatory No. 8 and No. 14; Sky Roberts; Lynn Roberts; Kimberley Roberts; Daniel LNU, half-brother of Plaintiff; Carol Roberts Kess; Philip Guderyon; Anthony Valladares; Anthony Figueroa; Ron Eppinger Response to Request No. 5 Ms. Giuffre objects to this request in that it is overly broad seeking documents relating to over 60 individuals. 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 19