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Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 33 of 40 Response to Request No. 27 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 objects to this request to the extent it seeks proprietary or copyright protected materials. Ms. Giuffre produces herewith documents bates labelled GIUFFRE000001 to GIUFFRE003 190 and will continue to supplement her production. Ms. Giuffre is withholding documents responsive to this request based on her objections. 28. All Documents reflecting notes of, or notes prepared for, any statements or interviews in which You referenced by name or other description, Ghislaine Maxwell. Response to Request No. 28 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 objects to this request to the extent it seeks proprietary or copyright protected materials. At this point in time, Ms. Giuffre has not found any non-privileged documents responsive to this request, but continues to search for responsive documents. 29. All Documents concerning any Communications by You or on Your behalf with any media outlet, including but not limited to the Daily Mail, Daily Express, the Mirror, National Enquirer, New York Daily News, Radar Online, and the New York Post, whether or not such communications were “on the record” or “off the record.” 32