Giuffre_Maxwell_Batch5_p00038.png
Extracted Text (OCR)
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 24 of 40
producing the paper copies she has in her possession, custody and control. The Defendant has
documents responsive to this request that she should produce.
9. Any Documents reflecting rental agreements or purchase agreements for the
residential addresses identified by You in response to Interrogatory No. 1.
Response to Request No. 9
Ms. Giuffre objects to this request in that it seeks confidential financial information that
is irrelevant to this action. 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 the information regarding rental agreements
for the apartments that Defendant and Jeffrey Epstein rented for her are in the Defendant’s
possession, control and custody. Ms. Giuffre objects to this request in that it is not limited to
rental agreements relevant to this action, so it is overly broad and unduly burdensome. Ms.
Giuffre produces is producing non-privileged documents bates labelled GIUFFRE000001 to
GIUFFRE003190 and will continue to supplement this production.
10. All Documents relating to Your Employment and/or association with the
Mar-a-Lago Club located in Palm Beach, Florida, including any application for
Employment.
Response to Request No. 10
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 produces herewith documents bates labelled GIUFFRE000001 to GIUFFRE003190 and
will continue to supplement this production.
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Dates
Document Details
| Filename | Giuffre_Maxwell_Batch5_p00038.png |
| File Size | 252.5 KB |
| OCR Confidence | 95.0% |
| Has Readable Text | Yes |
| Text Length | 1,742 characters |
| Indexed | 2026-02-04 12:43:51.552789 |