United States District Court

United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT GHISLAINE MAXWELL Plaintiff, by and through her undersigned counsel, hereby propounds Plaintiff's First Set of Interrogatories to Defendant Ghislaine Maxwell, pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure and Local Rule 33. The responses are due at the offices of Boies, Schiller & Flexner LLP, 401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida 33301, within thirty (30) days of service hereof. DEFINITIONS Wherever they hereafter appear the following words and phrases have the following meanings: 1. "Agent" shall mean any agent, employee, officer, director, attorney, independent contractor or any other person acting, or purporting to act, at the discretion of or on behalf of another. 2. "Correspondence" or "communication" shall mean all written or ve