Giuffre_Maxwell_Batch6_p00038.png
Extracted Text (OCR)
Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 30 of 48
Subject to and without waiving the above objections, Ms. Giuffre has already
produced documents Bates labelled GIUFFRE000001 to GIUFFRE005353, and will produce
non-privileged documents responsive to this Request and will continue to supplement her
production. Ms. Giuffre does not have “original, native format,” as requested so she is
producing the paper copies she has in her possession, custody and control. The Defendant has
documents responsive to this request that she should produce.
9. Any Documents reflecting rental agreements or purchase agreements for the
residential addresses identified by You in response to Interrogatory No. 1.
Response to Request No. 9
Ms. Giuffre objections to this Request on the grounds that it is overly broad and unduly
burdensome and calls for the production of documents that are irrelevant to this action and not
reasonably calculated to lead to the discovery of admissible evidence. 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 to the extent is seeks documents protected by the attorney client,
work product, joint defense, public interest or any other applicable privilege. Ms. Giuffre objects
to this request in that the information regarding rental agreements for the apartments that
Defendant and Jeffrey Epstein rented for her are in the Defendant’s possession, control and
custody.
Subject to and without waiving the above objections, Ms. Giuffre has already produced
documents Bates labelled GIUFFRE000001 to GIUFFRE005353, and will produce non-
privileged documents responsive to this Request, and will continue to supplement this
production.
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Extracted Information
Dates
Document Details
| Filename | Giuffre_Maxwell_Batch6_p00038.png |
| File Size | 254.5 KB |
| OCR Confidence | 95.3% |
| Has Readable Text | Yes |
| Text Length | 1,785 characters |
| Indexed | 2026-02-04 12:45:19.518152 |