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Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 26 of 40 request as it seeks documents of sealed juvenile records, and the only means of obtaining such records are either through court order or illegal means. Ms. Giuffre does not have any non-privileged documents responsive to this request. 14. Accopy of Your federal, state or local tax returns for the years 1998 to the present, whether from the United States or any other country. Response to Request No. 14 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 in that it seeks financial information from her when she was a minor child starting at age 14. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the agency privilege, investigative privilege, spousal privilege, accountant client privilege, and any other applicable privilege. Ms. Giuffre produces herewith documents bates labelled GIUFFRE000001 to GIUFFRE003190 and will continue to supplement this production. 15. All Documents concerning Your attendance at or enrollment in any school or educational program of whatever type, from 1998 to the present. Response to Request No. 15 Ms. Giuffre objects to this request to the extent is seeks documents protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the agency privilege, investigative privilege, spousal privilege, accountant client privilege, and any other applicable privilege. Ms. Giuffre objects to this request in that her school records from when she was a minor child are an invasion of privacy, and sought only to 25