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Case 1:17-mc-00025-RWS Document 1-5 Filed 06/13/16 Page 1 of 24
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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VIRGINIA L. GIUFFRE,
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
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DEFENDANT GHISLAINE MAXWELL’S RESPONSES AND OBJECTIONS TO
PLAINTIFF’S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS
Defendant Ghislaine Maxwell, by and through her undersigned counsel, hereby responds
to Plaintiff’s Second Request for Production of Documents (the “Requests”).
PRELIMINARY STATEMENT AND GENERAL OBJECTIONS
1. This response is made to the best of Ms. Maxwell’s present knowledge,
information and belief. Ms. Maxwell, through her attorneys of record, have not completed the
investigation of the facts relating to this case, have not completed discovery in this action, and
have not completed preparation for trial. Ms. Maxwell’s responses to Plaintiff’s requests are
based on information currently known to her and are given without waiving Ms. Maxwell’s right
to use evidence of any subsequently discovered or identified facts, documents or
communications. Ms. Maxwell reserves the right to supplement this Response in accordance
with Fed. R. Civ. P. 26(e).
2. Ms. Maxwell objects to the Requests to the extent they attempt to impose any
requirement or discovery obligation greater than or different from those under the Federal Rules
of Civil Procedure, the local rules of this Court or any Orders of the Court
[…]