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Giuffre_Maxwell_Batch5_p00044.png

Source: GIUFFRE_MAXWELL  •  Size: 256.4 KB  •  OCR Confidence: 94.9%
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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

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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