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EFTA02798033

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Case 1:15-cv-07433-LAP Document 194-1 Filed 06/06/16 Page 1 of 1 DOCUMENT REQUEST NO. 9 Produce any Joint Defense Agreement entered into between You and Alan Dershowitz from 1999 to the present. RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or information protected by the attorney/client privilege, the work-product doctrine, the common interest privilege or any other applicable privilege. Subject to and without waiver of the foregoing, Defendant has been unable to locate any documents responsive to this Request. DOCUMENT REQUEST NO. 10 Produce any documents concerning any Joint Defense Agreement entered into between You and Alan Dershowitz from 1999 to the present. RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or information protected by the attorney/client privilege, the work-product doctrine, the common interest privilege or any other applicable privilege. Subject to and without waiver of the foregoing, Defendant has been unable to locate any documents responsive to this Request. DOCUMENT REQUEST NO. 11 Produce any documents concerning any of Your attorneys' or agents' communications with Alan Dershowitz's attorneys or agents from 1999 to the present RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or information protected by the attorney/client privilege, the work-product doctrine, the common interest privilege or any other applicable privilege. Defendant is withholding communications between Mr. Dershowitz's counsel and Defendant's counsel which contain work product and concern joint defense or common interest matters. DOCUMENT REQUEST NO. 12 Produce all documents concerning (a4/a whether or not they reference her by name. This request includes, but is not limited to, all communications, diaries, journals, calendars, blog posts (whether published or not), notes (handwritten or not), memoranda, mobile phone agreements, wire transfer receipts, or any other document

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