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Case 1:17-mc-00025-RWS Document 10-6 Filed 06/30/16 Page 1 of 6
EXHIBIT F
Case 1:17-mc-00025-RWS Document 10-6 Filed 06/30/16 Page 2 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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Case 1:17-mc-00025-RWS Document 10-6 Filed 06/30/16 Page 3 of 6
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