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Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 22 of 40 i. Any of the individuals identified by You in response to Interrogatory No. 8 and No. 14. Response to Request No. 6 Ms. Giuffre objects to this request in that documents responsive to this request are 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 is producing herewith non- privileged documents bates labelled GIUFFRE000001 to GIUFFRE003 190 and will continue to supplement this production. Ms. Giuffre does not have “original, native format,” as requested so she is producing the paper copies she has in her possession, custody and control. The Defendant has documents responsive to this request that she should produce. 7. All photographs and video of You in any of Jeffrey Epstein’s properties, including, but not limited to: his home in Palm Beach, Florida; his home in New York City, New York; his ranch in Santa Fe, New Mexico; and Little Saint James island in the USS. Virgin Islands. To the extent You have such photographs and video in their original, native format, please produce them in that format (not a paper copy). Response to Request No. 7 Ms. Giuffre objects to this request in that documents responsive to this request are 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 21