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Giuffre_Maxwell_Batch5_p00038.png

Source: GIUFFRE_MAXWELL  •  Size: 252.5 KB  •  OCR Confidence: 95.0%
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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. 23

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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