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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT GHISLAINE MAXWELL'S RESPONSES AND OBJECTIONS TO PLAINTIFF'S SECOND REQUEST FOR PRODUCTION OF DOC
ITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT GHISLAINE MAXWELL'S RESPONSES AND OBJECTIONS TO PLAINTIFF'S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS Defendant Ghislaine Maxwell, by and through her undersigned co
XWELL, Defendant. X 15-cv-07433-RWS DEFENDANT GHISLAINE MAXWELL'S RESPONSES AND OBJECTIONS TO PLAINTIFF'S SECOND R
ECTIONS 1. This response is made to the best of Ms. Maxwell's present knowledge, information and belief. Ms.
t entities with which You are 19 EFTA00091371 associated, including but not limited to, funding received from the Clinton Global Initiative, the Clinton Foundation (a/k/a William J. Clinton Foundation, a/lc/a/ the Bill, Hilary & Chelsea Clinton Foundation), and the Clinton Foundation Climate Change Initiative.
KMBT_C654e-20190114185410
erg’s former investors rekindled the lawsuit against Epstein, but the case was dropped in October. Epstein and his associate, British-born socialite Ghislaine Maxwell, were also accused in a 2015 federal civil suit of organizing underage sex parties on his private plane, nicknamed “The Lolita Express,” and at Epste
Page: HOUSE_OVERSIGHT_016447 →in a 2015 federal civil suit of organizing underage sex parties on his private plane, nicknamed “The Lolita Express,” and at Epstein’s various homes. Maxwell, who has never been charged with wrongdoing, has denied allegations made in the lawsuit that she was Epstein’s “madam.” The suit, filed by victim Vir
Page: HOUSE_OVERSIGHT_016447 →Epstein and his associate, British-born socialite Ghislaine Maxwell, were also accused in a 2015 federal civi
Page: HOUSE_OVERSIGHT_016447 →Clinton, actor Kevin Spacey, comedian Chris Tucker and others to South Africa on his private jet as part of a fact-finding AIDS mission in support of the Clinton Foundation. But Epstein, a Clinton donor who contributed hundreds of thousands of dollars to Democratic candidates and causes, realized that his Democratic con
Page: HOUSE_OVERSIGHT_016447 →g’s former inves- tors rekindled the lawsuit against Epstein, but the case was dropped in October. Epstein and his associate, British-born socialite Ghislaine Maxwell, were alsoaccused in a 2015 federal civil suit of organizing underage sex par- ties on his private plane, nicknamed “The Lolita Express,” and at Epst
Page: HOUSE_OVERSIGHT_022210 →a 2015 federal civil suit of organizing underage sex par- ties on his private plane, nicknamed “The Lolita Express,” and at Epstein’s various homes. Maxwell, who has never been charged with wrongdoing, has denied allegations made in Jeffrey Epstein the lawsuit that she was Epstein’s “madam.” The suit, f
Page: HOUSE_OVERSIGHT_022210 →Epstein and his associate, British-born socialite Ghislaine Maxwell, were alsoaccused in a 2015 federal civil
Page: HOUSE_OVERSIGHT_022210 →Clinton, actor Kevin Spacey, comedian Chris Tucker and others to South Africa on his private jet as part of a fact-finding AIDS mission in support of the Clinton Foundation. But Epstein, a Clinton donor who contributed hundreds of thousands of dollars to Democratic candidates and causes, realized that his Demo- cratic c
Page: HOUSE_OVERSIGHT_022210 →gm.com/content /dam/Media/gmcom/investor/2018/feb/GM-2017-Q4-Earnings-Deck.pdf; “Annual Report.” Boein
2, 2017. https://www.pbs.org/newshour/politics/lawmakers-look-curb-foreign-influence-state -elections. 34 Vozella, Laura and Simon Denyer. “Donor to Clinton Foundation, McAuliffe Caught Up in Chinese Cash- for-Votes Scandal.” Washington Post. September 16, 2016. https://www.washingtonpost.com/local/virginia -politic
Entities connected to both Ghislaine Maxwell and Clinton Foundation

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONDoug Band
PERSONFBI
ORGANIZATION
Denver
LOCATIONEmmy Taylor
PERSON
Joe Biden
PERSON
Prince Charles
PERSON
New York City
LOCATION
John F. Kennedy
PERSON