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Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 21 of 40 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 objects to this request to the extent is seeks documents protected by the attorney client, work product, joint defense, investigative or any other applicable privilege. Ms. Giuffre objects to this request in that it is sought solely to harass and intimidate Ms. Giuffre, and invade her privacy, by seeking her private communications with her various family members, including aunts, uncles and parents and siblings. Ms. Giuffre is producing herewith non-privileged documents bates labelled GIUFFRE000001 to GIUFFRE003190 and will continue to supplement this production. 6. All photographs or video containing any image of You and the following individuals. To the extent You have such photographs and video in their original, native format, please produce them in that format (not a paper copy). a. Ghislaine Maxwell b. Alan Dershowitz ce. Jeffrey Epstein d. Andrew Albert Christian Edward, the Duke of York (aka Prince Andrew) e. Ron Eppinger f. _ Bill Clinton g. Stephen Hawking h. Al Gore 20