010-06.pdf

EXHIBIT F
Case 1:17-mc-00025-RWS Document 10-6 Filed 06/30/16 Page 1 of 6

United States District Court
Southern District of New York

Virginia L. Giuffre,
Plaintiff,
Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/

PLAINTIFF’S SECOND AMENDED SUPPLEMENTAL RESPONSE AND
OBJECTIONS TO DEFENDANT’S FIRST SET OF
DISCOVERY REQUESTS TO PLAINTIFF

Plaintiff hereby serves her second amended supplemental responses and objections to
Defendant’s First Set of Discovery Requests.

GENERAL OBJECTIONS

Defendant’s First Set of Discovery Requests violates Local Civil Rule 33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation of each category of damage alleged, and the
existence, custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore, they should not be served because they are not “a more practical
method of obtaining the information sought than a request for production or a deposition,” and
because they were served in advance of the period “30 days prior to the discovery cut-off date.”
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broad under Rule 26(b)(1), Fed. R. Civ. P. Specifically, Ms. Giuffre objects to the requests as
overly burdensome to the extent that they would require logging voluminous and ever-increasing
privileged communications between Ms. Giuffre and her counsel after the date litigation
commenced on September 21, 2015. Ms. Giuffre objects to the requests as overly burdensome to
the extent that they would require logging voluminous privileged documents between Ms.
Giuffre and her counsel related to Jane Doe #1 and Jane Doe #2 v. United States, Case no. 08-
80736-CIV-Marra, pending in the Southern District of Florida; Bradley Edwards and Paul
Cassell v. Alan Dershowitz, Case no. CACE 15-000072, pending in the Seventeenth Judicial
Circuit, Broward County, Florida; and Jane Doe No. 102 v. Jeffrey Epstein, Case No. 09-80656-
CIV-Marra/Johnson (Southern District of Florida). Accordingly, due the undue burden of
individually logging responsive privileged documents related to Defendant’s overly broad
requests, Plaintiff has employed categorical logging of such privileged responsive documents
pursuant to Local Civil Rule 26.2(c).

Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole
purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking. Ms.
Giuffre objects to the requests to the extent they are overly broad and unduly burdensome.

Ms. Giuffre objects to Defendant’s definition of “your attorneys” because it includes
names of attorneys that do not represent her, including Spencer Kuvin and Jack Scarola.

Ms. Giuffre’s responses to Defendant’s First Set of Discovery Requests are being made
after reasonable inquiry into the relevant facts, and are based only upon the information and
documentation that is presently known to her. Ms. Giuffre reserves the right to modify and/or
supplement her responses. Ms. Giuffre is producing documents and information herewith, and
she will continue to review and produce relevant documents until completion.
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Facebook account for a short time but it is no longer active. Per our representations during the
March 21, 2015 meet and confer phone call, we are working diligently to find information to
supplement the above information, and once that information is obtained, Plaintiff will serve
supplemental responses.

3. Identify each attorney who has represented you from 1998 to the present, the
dates of any such representation, and the nature of the representation.

Response to Interrogatory No. 3

Ms. Giuffre objects to this interrogatory as it seeks privileged information relating to her
representation by attorneys.

o Ms. Giuffre responds as follows: Bob Josefsberg, Katherine W. Ezell, Amy Ederi
(among other possible Podhurst Orseck, P.A. attorneys) represented Ms. Giuffre
as a party in the litigation styled as Jane Doe No. 102 v. Jeffrey Epstein, Case No.
09-80656-CIV-Marra/Johnson, starting on January 27, 2009.

o Stan Pottinger, David Boies, and Sigrid McCawley (along with other Boies
Schiller & Flexner LLP (“Boies Schiller”) attorneys) represented Ms. Giuffre as a
non-party in the litigation styled as Bradley Edwards and Paul Cassell v. Alan
Dershowitz, Case no. 15-000072, Seventeenth Judicial Circuit, Broward County,
Florida, starting in February, 2015.

o Brad Edwards (along with other Farmer, Jaffe, Weissing, Edwards, Fistos &
Lehrman, P.L. (“Farmer Jaffe”) attorneys), Paul Cassell, Stan Pottinger, David
Boies and Sigrid McCawley (along with other Boies Schiller attorneys) represent
Ms. Giuffre as a party in the litigation styled Giuffre v. Maxwell, 15-cv-07433-
RWS in the Southern District of New York, the complaint of which was filed in
September, 2015.

o Paul Cassell represents Ms. Giuffre as a non-party in the litigation styled as Jane
Doe #1 and Jane Doe #2 v. United States, Case No. 08-80736-CIV-Marra,
Southern District of Florida, starting in May of 2014.

o Brad Edwards (along with other Farmer, Jaffe attorneys) represents Ms. Giuffre
as a non-party in the litigation styled as Jane Doe #1 and Jane Doe #2 v. United
States, Case No. 08-80736-CIV-Marra, Southern District of Florida, starting in
2011.
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o Brad Edwards provided Ms. Giuffre with legal advice concerning media inquiries
Ms. Giuffre had received starting in 2011.

o Paul Cassell, Brad Edwards (along with other Farmer, Jaffe, attorneys), Stan
Pottinger, David Boies (along with other Boies Schiller attorneys) represented
Ms. Giuffre regarding investigations into potential legal action starting in the
second half of 2014.

o Paul Cassell, Brad Edwards (along with other Farmer, Jaffe, attorneys), Stan
Pottinger, David Boies, and Sigrid McCawley (along with other Boies Schiller
attorneys) represent Ms. Giuffre as a cooperating witness with regard to a law
enforcement investigation, starting in May, 2015.

o Paul Cassell provided Ms. Giuffre with legal advice concerning potential legal
action starting in early 2011.

o Paul Cassell and Brad Edwards (along with other Farmer, Jaffe, attorneys)
represented Ms. Giuffre and Victims Refuse Silence, giving advice regarding
Victims Refuse Silence, starting in October, 2014.

o Meg Garvin (law professor at Lewis & Clark Law School, and the Executive
Director of the National Crime Victim Law Institute ) represented Ms. Giuffre and
Victims Refuse Silence, giving advice regarding Victims Refuse Silence, starting
in October, 2014.

o Sigrid McCawley (along with other Boies Schiller attorneys) represented Ms.
Giuffre and Victims Refuse Silence, giving advice regarding Victims Refuse
Silence, starting in February 2015.

4. Identify each Communication, including the transmission of any Document, that
You or Your Attorneys have had with any local, state or federal law enforcement agent or
agency, whether in the United States or any other country, whether in Your capacity as a
purported victim, witness, or perpetrator of any criminal activity, and whether as a juvenile or as
an adult, including without limitation:
a. the date of any such Communication;
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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
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