Giuffre_Maxwell_Batch6_p00020.png
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Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 12 of 48
b. the form of any such Communication, whether oral or written and if
written, the format of any such Communication;
c. the identities of all persons involved in the Communication, including the
identity of the law enforcement agency with whom the agent is or was
affiliated;
d. the case number associated with any such Communication;
e. the subject matter of any such Communication;
f. the disposition of any case associated with any such Communication,
irrespective of whether the matter was sealed, expunged or later dismissed.
Response to Interrogatory No. 4
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre
objects to this interrogatory in that it seeks protected information regarding confidential
investigations. 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
public interest privilege, and any other applicable privilege. Ms. Giuffre objects to the extent
this seeks information regarding sexual assaults that occurred prior to her involvement with the
Defendant and Jeffrey Epstein. Ms. Giuffre responds as follows: Ms. Giuffre, in accordance
with the Court’s direction at the hearing on April 21, 2016, has submitted documents to the
Court for In Camera review. Ms. Giuffre met with the FBI on or about March 17, 2011. Ms.
Giuffre also corresponded with Maria Villafano from the U.S. Attorney’s office and that
correspondence has been produced.
5. Identify each Communication that You or Your Attorneys have had with any
author, reporter, correspondent, columnist, writer, commentator, investigative journalist,
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Document Details
| Filename | Giuffre_Maxwell_Batch6_p00020.png |
| File Size | 262.8 KB |
| OCR Confidence | 94.3% |
| Has Readable Text | Yes |
| Text Length | 1,772 characters |
| Indexed | 2026-02-04 12:45:16.468804 |