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Giuffre_Maxwell_Batch6_p00038.png

Source: GIUFFRE_MAXWELL  •  Size: 254.5 KB  •  OCR Confidence: 95.3%
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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. 29

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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