📧 Communication

This document outlines Ghislaine Maxwell's formal objections and responses to Virginia Giuffre's second request for production of documents in the 2015 civil case. Maxwell's counsel objects to numerous requests on grounds of privilege, relevance, and burden, specifically refusing to produce financial documents (tax returns, bank statements, asset lists) pending a motion for a protective order. The document also addresses requests for Joint Defense Agreements with Jeffrey Epstein and Alan Dershowitz, communications regarding sexual abuse allegations, and funding sources for the TerraMar Project, including any from the Clinton Foundation.