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munications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes,
ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,
No. 2 v. Epstein Page 17 Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting
admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
orking sites, and e-mails. Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 18. Any and all docume
unications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, t
ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,
ons who came to the New York Residence and who gave a massage or were asked to give a massage to Defendant. No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. No. 6. Identify all persons who came to the St. Thomas Residence and who gave
No. 2 v. Epstein Page 17 Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting
munications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes,
ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,
admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
No. 2 v. Epstein Page 17 Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting
munications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes,
ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,
admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
Entities connected to both Ghislaine Maxwell and the New Mexico Residence

Jeffrey Epstein
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONJane Doe
PERSON
Sarah Kellen
PERSON
Michael Jackson
PERSON
Jean-Luc Brunel
PERSON
Kenneth Marra
PERSON
Woody Allen
PERSONJack Goldberger
PERSONNadia Marcinkova
PERSONHaley Robson
PERSON
Jay Lefkowitz
PERSONFisher
PERSONRobert D. Critton
PERSON
Carson
PERSONFeldman
PERSONMichael J. Pike
PERSON
Jeffrey Marc Herman
PERSON