Giuffre_Maxwell_Batch6_p00055.png
Extracted Text (OCR)
Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 47 of 48
37. Statements or records from any bank into which You deposited money
received from Jeffrey Epstein, any Person identified in Interrogatory No. 8 or 14, any
witness disclosed in Your Rule 26(a) disclosures, any media organization or any employee
or affiliate of any media organization.
Response to Request No. 37
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 this request in that it seeks
personal financial information. Ms. Giuffre objects to this request in that it is overly broad as it
has no time limitation.
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.
Dated: April 29, 2016
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Meredith Schultz (Pro Hac Vice)
Boies Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
(954) 356-0011
David Boies
Boies Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
46
Document Details
| Filename | Giuffre_Maxwell_Batch6_p00055.png |
| File Size | 249.8 KB |
| OCR Confidence | 95.1% |
| Has Readable Text | Yes |
| Text Length | 1,413 characters |
| Indexed | 2026-02-04 12:45:25.483404 |