gov.uscourts.nysd.447706.223.1.pdf

Case 1:15-cv-07433-RWS Document 223-1 Filed 06/16/16 Page 1 of 14 EXHIBIT 1  Case 1:15-cv-07433-RWS Document 223-1 Filed 06/16/16 Page 2 of 14 Case 1:15-cv-07433-RWS Document 161-1 Filed 05/25/16 Page 2 of 40 ;\0 88/\ (Rev. 12/13) Subpoena to TestifY al a Deposition ill u Civil Action UNITED STATES DlSTRICT COURT fo!' the Southern District of New York .. . __.... _._yirgi,~i" L. Giuffre: ) PlainlUT ) v. ) Civil Action No. 15-CV-07433-RWS Ghislaine Maxwell ) ) DefendaJ1t ) SVBPOENA TO TESTIFY AT A BCPOS1TiON TN A CIVIL ACTWN To: JEFFRE:"Y EPSTEIN -<- .---_. (\'(Wk (,< rfl'O'1 h: lI'/;'Jl;; tfu" fiTestimony VOl) ARE COM3·1ANDED to appeal' at the time, date, and place set fClIih below to testify at a deposition to be taken in this civil action. If you are an organization, you must designate one or more orJicers. directors, or managing agents, OJ' designate other persons who consent to testify on your behalf about the following matters, or those set 101t11 in an attachment: ~:::,."""'" ··.. ·1 ,PhIC(;: BOiGs, SCflITfer&fiexilerTLP,57'5Cexrr:;gtorl ...... / . . ,.' ,1 D~t<., "nu 1 ;111" 1~'J(Jn1l8, N(x/ YorK, NY 10022; 954-356-00'1 '1 : 06/1'1/2016 at 9:00 a.m. ----'-- You, or YOllr representatives, must also bring with YOLl to the deposition the following documents, electronically stored information, or objectS, and mu~l pCn11it inspection, copying, testing, or sampling ofthe llwteriui; PLEASE SEE ATIACHED EXHIBIT A The Collowing provisions of Fed. R. Civ. P. 45 are attached - Rule 45(c), relating to the place of compliance; Rule ·j5(d), relating to your protection as a person subject to a subpoena; and Rul<> 45(0) and (g), relating to your duty to respond to this subpoena and the potential consequences of not doing so. Date: 05/13/20111 CLERK OF COURT OR Signature of Clel'k or Dep/ity CIeri; The name, address, e·m~lil :1,ka'0ss, and tdcpbone nun.!)(:r of' lile atlorn>?! repr~~sta1ting (nmllc ....yi.r9inia Giuffre. .._ __ . _..... ~ _. _. _.......__ . __ .. ..........__ .......... .. .........____ . , who j~;SH<C.S or rcque:;ts this subpoena, are: Sigrid S. McCawley, BSF, LLP, 401 E. Las Olas Blvd" #1200, Ft. Lauderdale, FL, 33301; 954-356-001'1; Notice to the persoll who issues or \'C(juests this subpoena If this subpoena commands the production of docllments, elec.tronically stored infol1l13tion, 01' tangible things, a notice and a copy of the suhpoena rt11lst be served on e"ch pm"!)' in this case before it is served 011 the penon to whom it is directed. Fed. R. Civ. P. 45(a)(4).  Case 1:15-cv-07433-RWS Document 223-1 Filed 06/16/16 Page 3 of 14 Case 1:15-cv-07433-RWS Document 161-1 Filed 05/25116 Page 3 of 40 AO 8M (Rev. 12/13) Subpoena to TeRtiI)' ata Deposition in ~ Civil Actioll (P"l\e 2) Civil Action No. 15·CV·07433·RVVS PROOF OF SERViCE (This see/ion should Iwt hI! flied with the COllrlunless required by Fed. R, Civ. P. 45.) I received this subpoen<l for (name o!indil'idua! alld tit/e, ({emy) on (do/c) o I served the subpoena by delivering a copy 10 the named individual as follows; on (dale) ; or o I returned the subpoena unexecuted because: TJnless th~ subpo<.ma was issued on behalf oflhe Urliled States, or one uf 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 S My fees arc $ for travel and S for services, for II total ofS 0.00 I declare under penalty ofpel~ury that this information is true. Date: Printed flame (lnd title Serve)' 's address Additional information regarding a11empted service, etc ..  Case 1:15-cv-07433-RWS Document 223-1 Filed 06/16/16 Page 4 of 14 Case 1:15-cv-07433-RWS Document 161-1 Filed 05/25/16 Page 4 of 40 AO SSA (ReI'. 12/13) Subpoenn to Testify uta Deposition in uCil'il Action (Page 3) Federal Rule of Civil ProcedUl'e 45 (c), (d), (e), and (g) (Effective 1211113) (,.) PhH~r of Compliance. (i) disclosing a trade secret or other confidential research, development, or commercial intormation; or (I) For (/ Trilll, Hearillg, or Depositioll. A subpoena may coml11and a (ii) disclosing 31lunretained cxpen's opinion or information that does pcrwll lO attend a IriHI, hearing, or deposition only a~ follows: nOI describe specific occurrences in dispute and resulls ['rom the expel1's (A) within 100 mil~s of where the person resides. is "mp1ovcd, or study that wns not requested by a party. regularly tTaMacts hl1sine~s in person; or • (C) Specifying Conditions as em Altematlve. [n the circumstances (8) withinlhe Slale where the perSOll resides, is employed. or regularly described in Rlile 4S(d)(3)(H), the court may, instead of quashing or transacts business in person, if the person modifying a subpoena. order appearance or production under speciticd (i) is a party or a p~rty's officer; or conditions if the serving party: (ii) is commanded 10 attend a trial and wlIuld llot incur substantial (i) shows a snbslantiulneed for the testimony or material that cannot be expense. otherwise Illet withom undue hardship; Dnd (ii) ensures r/tatthc subpoenaed person will be reasonably compensated. (2) For Other Discovery. A subpoena may command: (A) production of documents, electronically stored inlomlatiol1. or (e) Duties tn Responding to ~ Subpoena, tangible things at a place within 100 miles ofwllcrc the person resides, is cmployed. or regularly tnillsacts business in ]Jorson: and (1) Ptodllcing f)oculIlellts or Electrolliclilly Stored Illjormat/oll. These (E) inspection ofprcmises at the premises to be ins[l('cle.d. procedures apply to producing docliments or electronioally stored information: (d) I'l'Otccting 3 Person i;ubjcct to a Subpoena; Enforcement. (A) DoclIlI1ellls. A person responding to a subpoena to produce documents must produce them as tllCY are kept in lh~ ordinary COUTse of business or (I) A ,'oidiJlg Ulldlll': Burdell (lr E.'pellse,. SrmNiolJS. A party Ilr Rtlomey 11111St organize and lahel them to correspond to the categories in the demand. responsible for issuing and serving a subpoena must takc reasonable steps (S) FOl'mjor ProdUCing El~(:lronit;(/l/yS!ol'ed information Not Specified to avoid imposing undue burden or expense on a person subject (0 the If a subpoena does nol specify a fom) for producing electronically stored subpoena. The oourt tor the district where compliance is required must informalion, the person responding must produce it in a form or forms in cnu)rcC Ihis duty and impose an appropriate sonctioll-which may include which it is ordinarily mainlained or in u reasonably usable form or forms. lo~t c~rllil1gs and reasonable atloTl1~Y's tees--{)n a party or altorney who (e) Electronically Stored hl/omlOti{JII Produced in Only One Form. The fails 10 comply. person responding need not produce Ih~ same ele~lnmi~ally stored information in more than one form. (2) C(lmmalld to Produce Mllter/Ills or Permit IJlspectloll. (D) Inaccessible Electrol1ical~y Stored 1I1jormOli(l/I. The person (A) Appearallce Not Required. A person commanded (0 produce responding need not provide discovery of electronically stored information documents, electronically stored information. or tangible thing;;, Of to Irom SOllrces thnt the person identifies as not reasonably accessible because pemlit th~ inspection of premises, need not appear in person al the place of of undue burden or cost. On motion to compel discovery OJ for a protective production or inspection unless also comJ11floded to appear tor a deposition, order, the person responding mllst show that thc information is not heuring, or trial. reasonably accessible bccause of undue burden 01' cost. Htha! showing is (B) Objectiolls. A persoll communued to produce documenls or tangible made, the court may nonelheless order discovcry from such sources if Ihe lhings Of 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)(2)(C). The t'.ourt may speoify conditions fbr the discovery. sHmpl i ng any or 1111 oJ'the maleria!s or to inspecti ng the prem ises-or to produdng electronically slured information in the form or forms requesled. (2) Claimlllg PrMfege or Protectioll. The objection must be served before the earlier oftllc time specified (or (A) Informalion WilMeld. A person withholding subpoenaed inforrnu(ion compliance or 14 days after the suilpoena is served. Ifan objection is made. undor n claim thal it is privileged or subject to protection as triul.p,eparatioll the following rules apply: material muse (i) At ony time, on notice tQ the commanded perRon, the .~crviog party (I) expressly mak~ the claim; and rtllly I11lJve the court for rhc di.,triclll'hcre eolnplinoce is reqnired lor un (ill describe the mnurc oflhc withheld documents. communications, or order compelling production or i[1sp~clion. langible 1I1ings in a munner that .• withollt revcaling information ilself (iI) These aul, may be reqllired only as directed in the order, und lhe privileged or protected, will enable the parties to assess ille claim. order mllst protect a person who is neither II pHny nor a party'~ "metr tiol!) (U) Information Produced. If information produced in response to a signiflcant expen,~ r"~ulting from ~ompliallce. subpoena is sUbjecl to a claim of privilege Or of protection ns trial-preparation material. the person making the claim may notify any parlY (3) Quashing ()f Modifyi1lg (t Subpoenil, that received the iJifonnation ortlle claim and the basis tor it. After being notified, it party must promptly return, setjueswr, or destroy the specified (A) When Required 011 timely motion, the court for the district where infoImation and uny cl)pie,~ illtus; must no( lise or disclose the infollnution compliance is reqnired must quash or lllodi1)' a subpoena that: until the claim is re.solved; Inllst take reasonable steps to retrieve the infonllulioTJ if the paJty disclosed it before being notified; and may promptly (i) fails to allow a reasonable time to comply; present the information under sefll to the COlll·t for the district where (iI) requires a person to comply beyond the geographical limits compliance is required for a determination ofthc claim. The person who specified in Rule 45(c); produced the infonnalioll J11llst preserve (hc information unlil the claim is (iii) requires disclosure of privileged or other protected matter, if no resolved. exception or waiver applies; or (i 1') su~iects a person (0 undtw burden. (g) Contemllt. (U) When Permitlei!. To protect a person subject to or affected by u The court for the district wllere enmpliance is required-and also, after 11 subpoena. the court tor the district where compliance is re4uircu lIlay, on Illotion is transferred, the issuing court-may hold in contempt u persoll l1lotion, quash or mOdify Ihe subpoena ifit r,~qllir¢s: who, having been served, fails without udequllte excuse to obey the subpoena or 1m order reluted to it. For ac<'css IQ subpoena malerials, sec Fed. R. Civ. P. 45(a) Committee Nl\le (20) 3).  Case 1:15-cv-07433-RWS Document 223-1 Filed 06/16/16 Page 5 of 14 Case 1:15-cv-07433-RWS Document 161-1 Filed OS/25/16 Page 5 of 40 Jeffrey Epstein Wherever they hereail:er appear the following words and phrases have the following meanings: 1. "Agent" shall mean any agent, employee, ofticer, director, attomey, independent contractor or any other person acting, or purporting to act, at {he discretion of or on behalf of another. 2. "Correspondence" 01' "communlcation" 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 ston;:d, transmitted or received; and, includes every manner 01' means of disclosure, transfer or exchange, and every disclosure, transfer or exchange of inJormatioll whether orally or by Document or othenvise, taee-to-tace, by telephone, lelecopies, c-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 01' reproduced, and each and every thing from which information can be processed, transcribed, transmitted, restored, recorded, 01' memorialized in any 'Nay, by any means, regardle.ss of technology or form. It inc.ludes, without limitation, correspondence, memoranda, notes, notations, diaries, papers, books, accounts, newspaper and magazine articles, advertisements, photographs, videos, notebooks, ledgers, letters, telegrams, cables, telex messages, facsimiles, 2  Case 1:15-cv-07433-RWS Document 223-1 Filed 06/16/16 Page 6 of 14 Case 1:15-cv-07433-RWS Document 161-1 Filed 05/25116 Page 6 of 40 Jeffrey Epstein contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes, reports and recordings ofteJcphone or other conversations or communic.ations, or of interviews or conferences, 01' of other meetings, occurrences or transactions, affidavits, statements, sllmmaries, 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, e-maiIs, information kept in computer hard drives, other computer drivcs of any kind, computer tape back-up, CD-ROM, other computer disks of any kind, teletypes, teJecopics, invoices, worksheets, printed matter of every kind and dcsniption, graphic and oral records and representations of any kind, and electronic "writings" and "recordings" as set (()fth in the Federal Rules of Evidence, including but not limited to, originals or copies where originals are not aV<1i1able. Any Document with any marks s11ch as initials, comments or notations of any kind of not deemed to be identical with one wilhout such marks and is produced as a separate Document. Where there is any question about whether a tangible item otherwise described ill these requests falls within the definition of "Document" slIch tangible item shall be produced. 6. "Employee" includes a past or present officer, director, agent or servant, including any attorney (associate or palinel') or paralegal. 7. "Including" means including without limitation. g. "Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or coniTolled by Jeffrey Epstein, any employee, agent, attorney, consultant, or representative of Jeffrey Epstein. 3  Case 1:15-cv-07433-RWS Document 223-1 Filed 06/16/16 Page 7 of 14 Case 1:15-cv-07433-RWS Document 161-1 Filed 05/25/16 Page 7 of 40 Jeffi-ey Epstein 9. "GbisJaine 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 perSOIlS, proprietorships, governmental agencies, corporations, pmtncrships, trusts, joint ventures, groups, associations, organizations or any other Jegal or business entity, II. "You" or "Your" hereinafter l11eans Jeffj-ey Epstein and any employee, agent, attorney, consultant, related entities or other representative oncffi"cy Epstein. [)S'fH U(llQl"JS Production of Documents and items requested herein shall be made at the offices of Boies Schiller & Flexner, LLP, 401 East Las 01as Boulevard, Suite 1200, Fort Lauderdale, Florida 33301, no later than five (5) cJnys before the date noticed for Your deposition, or, jf 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 thc relevant time frame ifit refers or relates (0 communications, meetings or other events or DoclIments that occurred or were created \vithill that time frame, regardless of the date of creation of the responsive Document. 3. This Requcst calls for the production of alll'esponsive Documents in Your possession. custody or control without regard to the physical location of such Documents. 4. Ir any Document requested was in Your possession or control, but is no longer in its possession or control, sta.te whnt disposition was made of said Document, the reason for sllch disposition, and the date of such disposition. 4  Case 1:15-cv-07433-RWS Document 223-1 Filed 06/16/16 Page 8 of 14 Case 1:15-cv-07433-RWS Document 161-1 Filed 05/25116 Page 8 of 40 Jeffrey Epstein 5. For the purposes of reading, interpreting, or construing the scope of these requests, the terms llsed shall be given their most expansive and inclusive interpretation. This includes, without limitation tbe toll owing: 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 cOl~unc.1ively as necessary to bring within the scope hereof any information (as defmed 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. JfYou are unable to answer or respond fully to any Document request, answer or respond to the extent possible and specify the reasons for Your inability to answer or respond in full. Ifthc recipient has no Documents responsive to a paJiicular 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 \vords "relate," "relating," "relates," or any other derivative thereot~ as used herein includes concerning, referring to, responding to, relating to, pertaining to, connected with, comprising, memorializing, evidencing, commenting on, regarding, discussing, showing, describing, rcf1ectlng, analyzing or constituting. 9. "Identify" means, with respectto [\ny "person," or any reference to the "identity" of any "person," to provide the name, home address, telephone number, business name, business 5  Case 1:15-cv-07433-RWS Document 223-1 Filed 06/16/16 Page 9 of 14 Case 1:15-cv-07433-RWS Document 161-1 Filed 05/25/16 Page 9 of 40 Jef'ii-cy Epstein EXHmIT-A address, business telephone number, e-mail address, and a description of each such person's c.onnection \vitb the events in question. 10. "Identify" means, with I'espect to any "Document," 01' any reference to stating the "identification" of any "Document," provide 1he title and date of each slIch Document, the name and address of the parly Ot parties responsihle for the preparation of each such Document, the name and address of the party who requested or required the preparation and on whose behalfit was prepared, the name and address 0 f 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 Doeument or copies thereof. 11. In producing Documents, if the original of any Document cannot be located, a copy shall be produced in lieu thereot: and shall be legihle 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. Ifany requested Document cannot be produced in fulJ, produce the Document to the extent possible, spccifYing e,ach reason for Your inability to produce the remainder of the Document stating whatever information, knowledge 01' belief which You have concerning the portion not produced. 14. If any Document requested was at anyone time in existence but are no longer in existence, then so state, specif)ring for each Document (a) tbe type of Document; (b) the types of information contained thereon; (c) the dale upon which it ceased to exist; (d) the circumstances under which it ceased to exist; (e) the identity of all persall having knowledge ofthe 6  Case 1:15-cv-07433-RWS Document 223-1 Filed 06/16/16 Page 10 of 14 Case 1:15-cv-07433-RWS Document 161-1 Filed 05/25/16 Page 10 of 40 Jeffrey Epstdn circumstances under which it c.cascd to exist; and (t) the identity of all persons having knowledge or who had knmvlcdge onhe contents thereof and each individual's address. 15. All Documents shall be produced in the same order as they are kept or maintained by YOll 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 lIsed, ] 7. Documents attac.hed to each other shall not be separated. 18. Documents :;hall 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 wen~ found, and business address of each Document's custodian(s). 19. If any Documenl 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; (e) its date; (d) the name and address of each author; (c) the namc and addrcss of each of the addresses and/or individual to whom the Document vvas distributed, if any; (f) the title (01' position) of its author; (g) type oftangible object, e.g., Jetter, memorandum, telegram, chart, report, recording, disk, etc.; (h) its title and subject matter (without revealing the information as to .vhich the privilege is claimed); (i) with sufficient specificity to permit the Court to make fllll 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. 7  Case 1:15-cv-07433-RWS Document 223-1 Filed 06/16/16 Page 11 of 14 Case 1:15-cv-07433-RWS Document 161-1 Filed OS/25/16 Page 11 of 40 Jeffrey Epstein 20. If any Document requested herein is withheld, in all or part, based on a claim that slIch Do(.:ument constitutes attorney work product, provide all of the information described in Instruction No. 19 and also identity the litigation ill connection with \vhich the Document and the information it contains \vas 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 0[' any further infonnation, Documents, things, or information responsive to this Request, You are required to so stale by supplemc.;nling Your responses and producing sllch additional Documents to Plaintiff. 8  Case 1:15-cv-07433-RWS Document 223-1 Filed 06/16/16 Page 12 of 14 Case 1:15-cv-07433-RWS Document 161-1 Filed 05/25/16 Page 12 of 40 Jeff]-ey Epstein 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 Calk/a Virginia Giuffre) or Ghislaine -Maxwell. 2. All video tape~, audio lapes, 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 (Thislaine Maxwell, 4. All video tapes, audio tapes, phot-ob'Taphs, including film negatives or film slides, CD' 5, or any other print or electronic media depicting females under the age of 18 (or purporting to be under thc age of 18), including pornographic media, whether commercial or amatelll'. 5. All Documents ot' other media (including photographs) describing or depicting nude, or pal'lially nude, females in Your possession, including, but not limited to, all Documents or othcr media describing or depicting how such photographs were displayed in Your variolls residences. 6. All Documents ('elating to Virginia Roberts. 7. All Docllments relating to (jhislaine Maxwell, including all Documents related to communications with GhisJuine J\/Iaxwell from 1999 - present. 8. All Documents relating to any members ofGhislaine MaxI-vell's family, including all Documents related to communications \-vith any members of Ghislainc Maxwell's family Lhlrl1 1970 present. 9. All Doc;ulTlcnts related to communications with AIan Dcrshowitz from 1999 prcsent. 9  Case 1:15-cv-07433-RWS Document 223-1 Filed 06/16/16 Page 13 of 14 Case 1:15-cv-07433-RWS Document 161-1 Filed 05/25/16 Page 13 of 40 Jeffrey Epstein 10. All Documents relating lO, and all media depicting, any ofthe following individuals fj'om 1999 - present: Emmy Taylor, Eva Dubin, Glen Dubin, Alan Dershowitz, Jean Luc BruneI, Sarah Kellen (a/k/a Sara Kensington and Sarah Vickers), Nadia Marcinko va (alkJa Nadia Marcinko), Nadia Bjorlin, or any females under the age of 18. 11. All Documents relating to any agreements (including by not limited to confidentiality agreements, indemnification agreements, employment agreements, or agreements to pay legal fees) between You Ghislaine Maxwell, whether such agreements arc written, verbal, or merely llnderstood among the parties and not otherwise expressed, whether or not such agreements were ever executed 0)' carried out. ] 2. All Documents relating to any credit cards paid for by You that were used by Cihislaine Maxwell (or any related entity) or Virginia Giuffre from 1909 ... present. 13. All telephone records associated with You, including eell phone records, from 1999 present, that show any communications with Ghislaine Maxwell. 14. All Documents relating to calendars, schedules or appointments fol' You from 1999 present that relate to visits with, or communications with, Ghislaine Maxwell and females under the age of 18. 15. All Documents identi fying any indi viduals who provided You a massage. 16. All Documents identifying any individuals who You paid for sexual acts, either with You oj' with other individuals. 17. All Documents identifying any females recru.ited by Ghislaine Maxwell f01" either work, sexual acts, or companionship for You. 18. All Documents relating to any females Ghislaine Maxwell introduced to You. 19. A 11 Documents relating to any females You paid to perform any kind of service, 10  Case 1:15-cv-07433-RWS Document 223-1 Filed 06/16/16 Page 14 of 14 case 1:1!:l-CV-Uf4;J;J-RWS Document 161-1 Filed 05/25116 Page 14 of 40 Jeffrey Epstein including but not limited to, work as an assistant, a massage therapist, sex worker, or companion. 20. AI1 Documents relating to Your traveJ ii'om the period of 1999 - present, when that travel was either with Ghislainc Maxwell or another female, or to med GhislaineMaxwell or other females, including but not limited to commercial flights, helicopters, passport records, records indicating passengers traveling with You, hotel records, and credit card receipts. 21. All Documents relating to payments You made, whether as cash, stock, real estate, or in-kind, to Ghislaine Max\vell, or any related cntity to Ghislainc Maxwell, including the TerraMar Project. 22. All Documents identifying any individuals to whom Virginia Roberts provided a nmssage. 11