Giuffre_Maxwell_Batch5_p00044.png
Extracted Text (OCR)
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 30 of 40
Response to Request No. 21
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 for whom she claims a
joint defense privilege and defendant has refused to produce responsive documents. 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. At
this point in time, Ms. Giuffre has not found any documents responsive to this request, but
continues to search for responsive documents.
22. Acopy of Your marriage license(s) from 1999 to the present.
Response to Request No. 22
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.
23. All documents concerning Your naturalization application to Australia from
1999 to the present.
Response to Request No. 23
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
29
Extracted Information
Dates
Document Details
| Filename | Giuffre_Maxwell_Batch5_p00044.png |
| File Size | 256.4 KB |
| OCR Confidence | 94.9% |
| Has Readable Text | Yes |
| Text Length | 1,753 characters |
| Indexed | 2026-02-04 12:43:55.071118 |