EFTA00592742.pdf

09/13/2016 19:1 FAX 40002/0003 • base 1:15-cv-07433-RWS Document 433 Filed 09/15/16 Page 1 of 2 BO I E S, SCHILLER & FLEXNER LLP 401 EAST LAS OLAS BOULEVARD • SU:TE 200 • FORT LAuDEROA;..E FL 3330:-22i I • PH. 954.35600H • FAX 954.356.0022 Sigrid S. McCawley, Esq. smccawievabsnimeom September 13, 2016 -0) inEOWIE \.\ I SEP 1 12016 i VIA FASCIMILE 1212-805-79251 Honorable Judge Robert W. Sweet JUDGE SWEET CHAMBERS District Court Judge United States District Court 500 Pearl Street New York, NY 10007 USDC srwy DOCUMENT ELECTRU:\t - 4. 7t Y FII Re: Giuffre v. Maxwell, DOC it: Case No.: 15-cv-07433-RWS DATE FILED: fl Dear Judge Sweet: Plaintiff, Virginia Giuffre provides this Court with Notice of Non-Response to the Court's July 30, 2016 Order. Specifically, on June 20, 2016, this Court authorized the subpoenas to Nadia Marcinkova and Sarah Kellen to be served by alternative means. Ms. Giuffre served subpoenas as directed by the Court and set the depositions of Nadia Marcinkova and Sarah Kellen for July 21, 2016 at the Boies Schiller & Flexner offices in New York City. Neither of the witnesses appeared for their depositions. On July 25, 2016, Ms.Giuffre filed Plaintiffs Motion for a Finding of Civil Contempt Against Sarah Kellen For Ignoring Subpoena and For Associated Sanctions (308) and Plaintiffs Motion for a Finding of Civil Contempt Against Nadia Marcinkova For Ignoring Subpoena and For Associated Sanctions (310). In her motions, Plaintiff sought the following relief in order to compel the depositions of Nadia Marckinkova and Sarah Kellen: (1) that Nadia Marcinkova and Sarah Kellen be directed to appear for deposition (2) that Nadia Marcinkova and Sarah Kellen pay Giuffre's costs and reasonable attorney's fees associated with bringing the motion, and that (3) Nadia Marcinkova and Sarah Kellen be ordered to pay a civil penalty of $2500 per day for each day after which they fail to appear at the rescheduled deposition and any other sanction the court believes is just and proper. On July 30, 2016 the Court issued the following order: "ORDER: Plaintiffs Motions for a Finding of Civil Contempt against Sarah Kellen and Nadia Marcinkova shall be taken on submission returnable August 25, 2016. All papers shall be served in accordance with Local Civil Rule 6.1 and pursuant to this Courts previous orders. (Signed by Judge Robert W. Sweet on 7/30/2016) (cf)". WWW.BSFLLP COM EFTA00592742 09/13/2016 18:A Q0003/0003 ease1:15-cv-07433-RWS Document 433 Filed 09/15/16 Page 2 of 2 t BOIES. SCHILLER 8. FLExNER LLP Honorable Judge Sweet District Court Judge September 13, 2016 Page 2 Neither Nadia Marcinkova nor Sarah Kellen filed any response to the Plaintiffs Motion on or before August 25, 2016. In light of these facts, Ms. Giuffre provides notice to this Court that Plaintiffs Motion for a Finding of Civil Contempt as to Nadia Marcinkova and Sarah Kellen remain pending. As indicated in that motion, Ms. Giuffre would respectfully request that the Court Order that (1) that Nadia Marcinkova and Sarah Kellen be directed to appear for deposition (2) that Nadia Marcinkova and Sarah Kellen pay Giuffre's costs and reasonable attorney's fees associated with bringing the motion, and that (3) Nadia Marcinkova and Sarah Kellen be ordered to pay a civil penalty of S3 6 per day for each day after which they fail to appear at the rescheduled deposition an any other sanction the court believes is just and proper. • Sincerely, Sigrid S. McCat4ley, Esq. SSM Enclosure 5 n cc; Counsel of Record 7 -asOci- Lc/4 EFTA00592743  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 RE-NOTICE OF RULE 45 SUBPOENA AND RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM OF SARAH KELLEN (A/K/A SARA KENSINGTON AND SARAH VICKERS) PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal Rules of Civil Procedure, the undersigned counsel hereby provides Notice of Taking the Videotaped Deposition Duces Tecum of Sarah Kellen (a/k/a Sara Kensington and Sarah Vickers). Pursuant to Rule 45, the undersigned counsel also hereby provides Notice of Service of Subpoena upon Sarah Kellen (a/c/a Sara Kensington and Sarah Vickers). A copy of the Subpoena is attached to this Notice. NAME: Sarah Kellen (aka Sara Kensington and Sarah Vickers) DATE AND TIME: October 12, 2016 at 1:30 p.m. LOCATION: Boles Schiller & Flexner, LLP 575 Lexington Avenue New York, NY 10022 The videotaped deposition will be taken upon oral examination before Magna Legal Services, or any other notary public authorized by law to take depositions. The oral examination will continue from day to day until completed. The deponent is requested to produce the items listed on Schedule "A' attached hereto at the time of the deposition. This deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the rules of this Court. EFTA00592744 Dated: September 26, 2016. BOLES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Mac Vice) Meredith Schultz (Pro Mac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro I lac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-5202' This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. EFTA00592745  AO XS.% (Re,. 12 4) Si rkV0.1 :0 i tql1\ .11 .1 ikrIONition Ill a CI\ :I Action UNITED STATES DISTRICT COURT for the Southern District of New York Virginia L. Giuffre v. Civil Action No. 15-cv-07433-RWS Ghislaine Maxwell ._ Deferukurt SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION To: SARAH KELLEN (NK/A SARA KENSINGTON AND SARAH VICKERS) (Nome ofperson to whom this subpoena is directed) fir Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a deposition to be taken in this civil action. If you arc an organization, you must designate one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or those set forth in an attachment: Boies. Schiller & Flexner LLFI Date and Time: 575 Lexington Avenue 10/12/2016 1:30 pm L New York, NY 10022 (954) 356-0011 The deposition will be recorded by this method: Stenographically and Videotaped I Production: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and must permit inspection, copying. testing, or sampling of the material: See attached Exhibit A. The following provisions of Fed. R. Civ. P. 45 are attached — Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g). relating to your duty to respond to this subpoena and the potential consequences of not doing so. Date: 09126/2016 CLERK OF COURT OR Signature ofClerk or Deputy Clerk Attorn‘signa es (ure The name, address. e-mail address, and telephone number of the attorney representing (name ofparty) Virginia Giuffre , who issues or requests this subpoena, are: Sigrid McCawley, Spies, Schiller & Flexner LLP, 401 E. Las Olas Blvd., #1200, Ft. Lauderdale, FL 33301; 954-356-0011; Eawroawieyeabst44.40a Notice to the person who issues or requests this subpoena If this subpoena commands the production of documents, electronically stored information, or tangible things before trial, a notice and a copy of the subpoena must be served on each party in this case before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4). EFTA00592746 AO NSA (Rev O2/I4) Subpocivs to Te.16 at a Depositton ina CI% it Act:on (Pae:c Civil Action No. 15-cv-07433-RWS PROOF OF SERVICE (This section should not bead with the court unless required by Fed. R. (iv. P. 45.) I received this subpoena for (name of individual and title. tfano on Nato O I served the subpoena by delivering a copy to the named individual as follows: on (date) ; or O I returned the subpoena unexecutcd because: Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of $ My fees are $ for travel and $ for services, for a total of S 0.00 I declare under penalty of perjury that this information is true. Date: Server's signature Printed name and title Server's address Additional information regarding attempted service, etc.: EFTA00592747 AO SSA (Rev 02/14) Subpoena to Testify at a Deposition in a Civil Action (Page 3) Federal Rule of Civil Procedure 45 (e), (d), (e), and (g) (Effective 12/1/13) (c) Place of Compliance. (I) disclosing a trade secret or other confidential research. development, or commercial information; or (I) For a Trial. Hearing. or Deposition. A subpoena may command a (ii) disclosing an unretaincd expert's opinion or information that does person to attend a trial, hearing. or deposition only as follows: not describe specific occurrences in dispute and results from the expert's (A) within 100 miles of where the person resides, is employed. or study that was not requested by a party. regularly transacts business in person. or (C)SpectfringeOMNIONTS at an Alternative. In the circumstances (B) within the slate where the person resides, is employed. or regularly described in Rule 45(d)(3)(BE the court may. instead of quashing or transacts business in person. if the person modifying a subpoena. order appearance or production under specified (i) is a party or a party's officer: or conditions if the serving party: (ii) is commanded to attend a trial and would not incur substantial (i) shows a substantial need for the testimony or material that cannot be expense. otherwise met without undue hardship: and (ii) ensures that the subpoenaed person will be reasonably compensated. (2) For Other Discovery. A subpoena may command: (A) production of documents, electronically stored information, or (e) Duties in Responding to a Subpoena. tangible things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and (I) Producing Documents or Electronically Stored information. These (B) inspection of premises at the premises to be inspected. procedures apply to producing documents or electronically stored information: (d) Protecting a Person Subject to a Subpoena: Enforcement. (A)Doeumenst A person responding to a subpoena to produce documents must produce them as they arc kept in the ordinary course of business or (I) Avoiding Undue Burden or Expense; Sanctions. A party or attorney must organise and label them to correspond to the categories in the demand. responsible for issuing and serving a subpoena must take reasonable steps (B) Formfor Producing Electronically StoredInformation Not Specyied to avoid imposing undue burden or expense on a person subject to the If a subpoena does not specify a form for producing electronically stored subpoena. The court for the district where compliance is required must information. the person responding must produce it in a form or forms in enforce this duty and impose an appropriate sanction—which may include which it is ordinarily maintained or in a reasonably usable form or forms lost earnings and reasonable attorneys fees—on a party or attorney who (Al Electroincallv Stored Information Produced in Only One Form. The fails to comply. persun responding need not produce the same electronically stored information in more than one form (2) Command to Produce Materials or Pernik inspection. (D) inaccessible Electronically Stored Information. The person (A) Appearance Not Required. A person commanded to produce responding need not provide discovery ofelectronically stored information documents, electronically stored information. or tangible things, or to from sources that the person identifies as not reasonably accessible because permit the inspection of premises. need not appear in person at the place of of undue burden or cost On motion to compel discovery or for a protective production or inspection unless also commanded to appear for a deposition. order, the person responding must show that the information is not hearing. or trial. reasonably accessible because of undue burden or cost. If that showing is (8)Objections. A person commanded to produce documents or tangible made, the court may nonetheless order discovery from such sources if the things or to permit inspection may serve on the party or attorney designated requesting party shows good cause, considering the limitations of Rule in the subpoena a written objection to inspecting. copying, testing. or 26(b)I2$C). The court may specify conditions for the discovery. sampling any or all of the matenals or to inspecting the premises—or to producing electronically stored information in the limn or forms requested. (2) Claiming Privilege or Protection, The objection must be served before the earlier of the time specified for (A) Information Withheld A person withholding subpoenaed information compliance or 14 days alter the subpoena is served. If an objection is made. under a claim that it is privileged or subject to protection as trial-preparation the following rules apply: material must: (i) At any time. on notice to the commanded person, the serving party (i) expressly make the claim: and may move the court for the district when:compliance is required for an (II) describe the nature of the withheld documents. communications, or order compelling production or inspection. tangible things in a manner that, without revealing information itself (ii) These acts may be required only as directed in the order, and the privileged or protected. will enable the panics to assess the claim. order must protect a person who is neither a party nor a party's officer from (B) Information Produced If information produced in response to a significant expense resulting from compliance. subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party (3) Quashing or Modifying a Subpoena. that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester. or destroy the specified (A) When Required. On timely motion, the court for the district where information and any copies it has; must not use or disclose the information compliance is required must quash or modify a subpoena that: until the claim is resolved; must take reasonable steps to retrieve the information if the pasty disclosed it before being notified: and may promptly (I) fails to allow a reasonable time to comply; present the information under seal to the court for the district where Oil requires a person to comply beyond the geographical limits compliance is required for a determination of the claim. The person who specified in Rule 45(c); produced the information must preserve the information until the claim is (iii) requires disclosure of privileged or other protected matter, if no resolved. exception or waiver applies: or (is') subjects a person to undue burden. (g) Contempt. (B) When Permitted To protect a person subject to or affected by a The court for the district where compliance is required—and also, alter a subpoena. the court for the district where compliance is required may. on motion is transferred, the issuing court—may hold in contempt a person motion, quash or modify the subpoena if it requires: who, having been served. fails without adequate excuse to obey the subpoena or an order related to it. For access to subpoena materials. sec Fed R. Civ P 4500 Committee Note (2013) L EFTA00592748  Sarah L. Kellen (a/lc/a Sara Kensington and Sarah Vickers) EXHIBIT A DEFINITIONS Wherever they hereafter appear the following words and phrases have the following meanings: I. "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 verbal communications, by any and all methods, including without limitation, letters, memoranda, and/or electronic mail, by which information, in whatever form, is stored, transmitted or received; and, includes every manner or means of disclosure, transfer or exchange, and every disclosure, transfer or exchange of information whether orally or by document or otherwise, face-to-face, by telephone, telecopies, e-mail, text, modem transmission, computer generated message, mail, personal delivery or otherwise. 3. "Plaintiff" in the above captioned action shall mean the plaintiff Virginia Giuffre formerly known as Virginia Roberts. 4. "Defendant" in the above captioned action shall mean the defendant Ghislaine Maxwell and her employees, representatives or agents. 5. "Document" shall mean all written and graphic matter, however produced or reproduced, and each and every thing from which information can be processed, transcribed, transmitted, restored, recorded, or memorialized in any way, by any means, regardless of technology or form. It includes, without limitation, correspondence, memoranda, notes, notations, diaries, papers, books, accounts, newspaper and magazine articles, advertisements, 2 EFTA00592749 Sarah L. Kellen (a/k/a Sara Kensington and Sarah Vickers) EXHIBIT A photographs, videos, notebooks, ledgers, letters, telegrams, cables, telex messages, facsimiles, contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes, reports and recordings of telephone or other conversations or communications, or of interviews or conferences, or of other meetings, occurrences or transactions, affidavits, statements, summaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income statements, statistical records, desk calendars, appointment books, lists, tabulations, sound recordings, data processing input or output, microfilms, checks, statements, receipts, summaries, computer printouts, computer programs, text messages, c-mails, information kept in computer hard drives, other computer drives of any kind, computer tape back-up, CD-ROM, other computer disks of any kind, teletypes, telecopies, invoices, worksheets, printed matter of every kind and description, graphic and oral records and representations of any kind, and electronic "writings" and "recordings" as set forth in the Federal Rules of Evidence, including but not limited to, originals or copies where originals are not available. Any document with any marks such as initials, comments or notations of any kind of not deemed to be identical with one without such marks and is produced as a separate Document. Where there is any question about whether a tangible item otherwise described in these requests falls within the definition of "Document" such tangible item shall be produced. 6. "Employee" includes a past or present officer, director, agent or servant, including any attorney (associate or partner) or paralegal. 7. "Including" means including without limitation. 8. "Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or controlled by Jeffrey Epstein, any employee, agent, attorney, consultant, or representative of Jeffrey Epstein. 3 EFTA00592750 Sarah L. Kellen (a/k/a Sara Kensington and Sarah Vickers) EXHIBIT A 9. "Ghislaine Maxwell" includes Ghislaine Maxwell and any entities owned or controlled by Ghislaine Maxwell, any employee, agent, attorney, consultant, or representative of Ghislaine Maxwell. 10. "Person(s)" includes natural persons, proprietorships, governmental agencies, corporations, partnerships, trusts, joint ventures, groups, associations, organizations or any other legal or business entity. 11. "You" or "Your" hereinafter means Sarah L. Kellen (a/k/a Sara Kensington and Sarah Vickers) and any employee, agent, attorney, consultant, related entities or other representative of Sarah 1,. Kellen (a/k/a Sara Kensington and Sarah Vickers). INSTRUCTIONS t. Production of Documents and items requested herein shall be made at the offices of Boies Schiller & Flexner, LLP, 401 East Las Olas Blvd., Suite 1200, Ft. Lauderdale, FL, 33301, no later than five (5) days before the date noticed for Your deposition, or, if an alternate date is agreed upon, no later than five (5) days before the agreed-upon date. 2. Unless indicated otherwise, the Relevant Period for this Request is from 1999 to the present. A Document should be considered to be within the relevant time frame if it refers or relates to communications, meetings or other events or Documents that occurred or were created within that time frame, regardless of the date of creation of the responsive Document. 3. This Request calls for the production of all responsive Documents in Your possession, custody or control without regard to the physical location of such Documents. 4 EFTA00592751 Sarah L. Kellen (a/k/a Sara Kensington and Sarah Vickers) EXHIBIT A 4. If any Document requested was in Your possession or control, but is no longer in its possession or control, state what disposition was made of said Document, the reason for such disposition, and the date of such disposition. 5. For the purposes ofreading, interpreting, or construing the scope of these requests, the terms used shall be given their most expansive and inclusive interpretation. This includes, without limitation the following: a) Wherever appropriate herein, the singular form of a word shall be interpreted as plural and vice versa. b) "And" as well as "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope hereof any information (as defined herein) which might otherwise be construed to be outside the scope of this discovery request. c) "Any" shall be understood to include and encompass "all" and vice versa. d) Wherever appropriate herein, the masculine form of a word shall be interpreted as feminine and vice versa. e) "Including" shall mean "including without limitation." 6. If You are unable to answer or respond fully to any Document request, answer or respond to the extent possible and specify the masons for Your inability to answer or respond in full. If the recipient has no Documents responsive to a particular Request, the recipient shall so state. 7. Unless instructed otherwise, each Request shall be construed independently and not by reference to any other Request for the purpose of limitation. 8. The words "relate," "relating," "relates," or any other derivative thereof, as used herein includes concerning, referring to, responding to, relating to, pertaining to, connected with, 5 EFTA00592752 Sarah L. Kellen (aAtta Sara Kensington and Sarah Vickers) EXHIBIT A comprising, memorializing, evidencing, commenting on, regarding, discussing, showing, describing, reflecting, analyzing or constituting. 9. "Identify" means, with respect to any "person," or any reference to the "identity" of any "person," to provide the name, home address, telephone number, business name, business address, business telephone number, e-mail address, and a description of each such person's connection with the events in question. 10. "Identify" means, with respect to any "Document," or any reference to stating the "identification" of any "Document," provide the title and date of each such Document, the name and address of the party or parties responsible for the preparation of each such Document, the name and address of the party who requested or required the preparation and on whose behalf it was prepared, the name and address of the recipient or recipients to each such Document and the present location of any and all copies of each such Document, and the names and addresses of all persons who have custody or control of each such Document or copies thereof. 11. In producing Documents, if the original of any Document cannot be located, a copy shall be produced in lieu thereof, and shall be legible and bound or stapled in the same manner as the original. 12. Any copy of a Document that is not identical shall be considered a separate Document. 13. If any requested Document cannot be produced in full, produce the Document to the extent possible, specifying each reason for Your inability to produce the remainder of the Document stating whatever information, knowledge or belief which You have concerning the portion not produced. 6 EFTA00592753 Sarah L. Kellen (a/lc/a Sara Kensington and Sarah Vickers) EXHIBIT A 14. If any Document requested was at any one time in existence but are no longer in existence, then so state, specifying for each Document (a) the type of Document; (b) the types of information contained thereon; (c) the date upon which it ceased to exist; (d) the circumstances under which it ceased to exist; (e) the identity of all person having knowledge of the circumstances under which it ceased to exist; and (0 the identity of all persons having knowledge or who had knowledge of the contents thereof and each individual's address. 15. All Documents shall be produced in the same order as they are kept or maintained by You in the ordinary course of business. 16. You are requested to produce all drafts and notes, whether typed, handwritten or otherwise, made or prepared in connection with the requested Documents, whether or not used. 17. Documents attached to each other shall not be separated. 18. Documents shall be produced in such fashion as to identify the department, branch or office in whose possession they were located and, where applicable, the natural person in whose possession they were found, and business address of each Document's custodian(s). 19. If any Document responsive to the request is withheld, in all or part, based upon any claim of privilege or protection, whether based on statute or otherwise, state separately for each Document, in addition to any other information requested: (a) the specific request which calls for the production; (b) the nature of the privilege claimed; (c) its date; (d) the name and address of each author; (e) the name and address of each of the addresses and/or individual to whom the Document was distributed, if any; (t) the tide (or position) of its author; (g) type of tangible object, e.g., letter, memorandum, telegram, chart, report, recording, disk, etc.; (h) its title and subject matter (without revealing the information as to which the privilege is claimed); (i) 7 EFTA00592754 Sarah L. Kellen (a/k/a Sara Kensington and Sarah Vickers) EXHIBIT A with sufficient specificity to permit the Court to make full determination as to whether the claim of privilege is valid, each and every fact or basis on which You claim such privilege; and (j) whether the Document contained an attachment and to the extent You are claiming a privilege as to the attachment, a separate log entry addressing that privilege claim. 20. If any Document requested herein is withheld, in all or part, based on a claim that such Document constitutes attorney work product, provide all of the information described in Instruction No. 19 and also identify the litigation in connection with which the Document and the information it contains was obtained and/or prepared. 21. Plaintiff does not seek and does not require the production of multiple copies of identical Documents. 22. This Request is deemed to be continuing. If, after producing these Documents, You obtain or become aware of any further information, Documents, things, or information responsive to this Request, You are required to so state by supplementing Your responses and producing such additional Documents to Plaintiff. 8 EFTA00592755 Sarah L. Kellen (aAda Sara Kensington and Sarah Vickers) EXHIBIT A DOCUMENTS TO BE PRODUCED PURSUANT TO THIS SUBPOENA 1. All video tapes, audio tapes, photographs, including film negatives or film slides, CD's, or any other print or electronic media depicting You in the presence of Virginia Roberts (a/k/a Virginia Giuffre), or in the presence of, or working for, Jeffrey Epstein or Ghislaine Maxwell. 2. All video tapes, audio tapes, photographs, including film negatives or film slides, CD's, or any other print or electronic media depicting Virginia Roberts. 3. All video tapes, audio tapes, photographs, including film negatives or film slides, CD's, or any other print or electronic media depicting Jeffrey Epstein. 4. All video tapes, audio tapes, photographs, including film negatives or film slides, CD's, or any other print or electronic media depicting Ghislaine Maxwell. 5. All video tapes, audio tapes, photographs, including film negatives or film slides, CD's, or any other print or electronic media depicting any female agent, employee, or companion of Jeffrey Epstein and Ghislaine Maxwell. 6. All Documents that relate to: Virginia Roberts, Jeffrey Epstein, Ghislaine Maxwell, or any female agent, employee, or companion of Jeffrey Epstein or Ghislaine Maxwell. 7. All Documents relating to communications with Jeffrey Epstein from 1999 — present. 8. All Documents relating to communications with Ghislaine Maxwell from 1999 — present. 9. All Documents related to communications with Alan Dershowitz from 1999 present. 9 EFTA00592756 Sarah L. Kellen (a/k/a Sara Kensington and Sarah Vickers) EXHIBIT A 10. All Documents relating to, and all media depicting, any of the following individuals from 1999 — present: Emmy Taylor, Eva Dubin, Glen Dubin, Alan Dershowitz, Jean Luc Brunel, Teala Davies, Nadia Bjorlin, Nadia Marcinkova (a/k/a Nadia Marcinko), Cindy Lopez, and Michelle Tagliani. 11. All video tapes, audio tapes, photographs or any other print or electronic media created at a time when You were at, or nearby, Jeffrey Epstein or Ghislaine Maxwell's residences, hotel rooms/suites, automobiles, or aircraft. 12. All Documents relating to Your travel from the period of 1999 — present, when that travel was either with Ghislaine Maxwell or Jeffrey Epstein, to meet Ghislaine Maxwell or Jeffrey Epstein, or paid for by Ghislaine Maxwell or Jeffrey Epstein, including but not limited to commercial flights, helicopters, passport records, records indicating passengers traveling with You, hotel records, and credit card receipts. 13. All Documents relating to payments made from Jeffrey Epstein, Ghislaine Maxwell, or any related entity to You, or to any company You own or control. 14. All Documents relating to or describing any work You performed with Jeffrey Epstein, Ghislaine Maxwell, or any affiliated entity from 1999 — present. 15. All Documents relating to any confidentiality agreements You executed relating to Jeffrey Epstein or Ghislaine Maxwell. 16. All Documents relating to any credit cards used that were paid for by Jeffrey Epstein, Ghislaine Maxwell, or any related entity from 1999 — present. 10 EFTA00592757 Sarah L. Kellen (a/k/a Sara Kensington and Sarah Vickers) EXHIBIT A 17. All telephone records associated with You, including cell phone records, from 1999 — present, that show any communications with Jeffrey Epstein, Ghislaine Maxwell, or Virginia Roberts. 18. All Documents relating to calendars, schedules or appointments for You from 1999 — present that relate to visits with, or communications with, either Jeffrey Epstein or Ghislaine Maxwell. 19. All Documents identifying any individuals to whom You provided a massage. 20. All Documents identifying any individuals who provided Jeffrey Epstein a massage. 21. All Documents identifying any females recruited by Ghislaine Maxwell for either work or companionship for either Ghislaine Maxwell or Jeffrey Epstein. 22. All Documents relating to any females that You introduced to Jeffrey Epstein or Ghislaine Maxwell. 23. All Documents relating to any females paid by Jeffrey Epstein or Ghislaine Maxwell to perform any kind of service, including but not limited to, work as an assistant, a massage therapist, or companion. 11 EFTA00592758