X-2HIBI-3T Case Document Filed Page of United States District Court Southern District New7.2 York Virginia Giuffre,-5 Plaintiff 2750Case No Ghislain6e Defendant NOTICE SERVICE OF RUL-3.5E SUB-3.5P-4.7OENA DUCES UPON JEFFREY EPSTEIN PLEASE TAKE NOTI-6.1CE THAT pursuant to Rule of th Federal Rules of Civil Procedure P6.3l-2.1aintiff Virginia Giuffre he reby provides Notice of Service of Subpoena upon Jeffrey Epstein A copy of the Subpoena is attached to this No tice as Exhibit A Dated April By S6.4i-2grid McCawley Sigrid McC7.6a-.6wley Adm9itted Hac Vice5 Boies Schiller Flexner LLP Las Olas Blvd Suite Ft Lauderdale FL David Boies Boies Schiller Flexner LLP Main Street NY Case Document Filed Page of Case Document Filed Page of AO Rev Subpoena to Testify at a Dep sition in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of New York Virginia Giuffre Plaintiff Civil Action No To Ghislaine Maxwell Defendant SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION JEFFREY EPSTEIN Name of person lo whom this subpoena is directed erf est imony 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 are 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 Place Boies Schiller Flexner LLP Las Olas Blvd Fort Lauderdale FL Date and Time The deposition will be recorded by this method Videography and Stenography 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 PLEASE SEE ATTACHED EXHIBIT A The following provisions of Fed Civ are attached Rule relating to the place of compliance Rule relating to your protection as a person subject to a subpoena and Rule and relating to your duty to respond to this subpoena and the potential consequences of not doing so Date CLERK OF COURT OR Signature o_ Clerk or Deputy Clerk 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 BSF LLP Las Olas Blvd Ft Lauderdale FL smccawley bsfllp com Notice to the person who issues or requests this subpoena If this subpoena commands the production of documents electronically stored information or tangible things 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 Civ a AO Rev Subpoena to Testify a Deposition in a Civil Action Page Civil Action No PROOF OF SERVICE This section should not be filed with the court unless required by Fed Civ I received this subpoena for 8.1(name of individual and title if any on 8.1(date I served the subpoena delivering a copy-7.1 to the nam8e1.9d individual as follows on 8.1(date or I returned the subpoena unexecuted 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 attendance and the m7.8ileage allowed law in the am7.8ount of fees are travel and services for a total of I declare under penalty-7.2 of perjury-7.2 that this inform7.9ation is true Date Server?s signature Printed name and title Server?s address Additional inform8ation regarding attem8pted service etc Case Document Filed Page of AO Rev Subpoena to Testify a Deposition in a Civil Action Page Federal Rule of Civil Procedure and Effective Place of Compliance For a Trial Hearing or Deposition A subpoena a person to attend a trial hearing or deposition only as f8.2o-2.1llows A within m5.6iles of8 where the person resides is em5.6ployed or regularly transacts business in person or within the state where the person resides is em5.7ployed or regularly transacts business in person if8 the person i is a party or a party?s or ii is com5.8m5.8a-2nded to attend a trial and would not incur substantial expense For Other Discovery A subpoena A production docum6ents electroni9.8cally stored inf8.4o-1.9rm6ation or tangible things at a place within m14.1iles where the person resides is em5.7ployed or regularly transacts business in person and inspection prem5.4i-.8ses at the prem5.4i-.8ses to be inspected Protecting a Person Subject to a Subpoena Enforcement Avoiding Undue Burden or Expense Sanctions A party or attorney responsible issuing and serving a subpoena take reasonable steps to avoid im6.6posing undue burden or expense on a person subject to the subpoena The court the district where com6.1p-1.8liance is required enf8.6o-1.7rce this duty and im6.2pose an appropriate sanction?which include lost earnings and reasonable attorney?s8.5 f8.7ees?on a party or attorney who to comply Command to Produce Materials or Permit Inspection A Appearance Not Required A person to produce docum5.6ents electronically stored inf8o-6.7rm5.6ation or tangible things or to perm5.7it the inspection prem5.7i-.8ses need not appear in person at the place of production or inspection unless also to appear a deposition hearing or trial Objections A person to produce docum6.6ents or tangible things or to permit inspection may serv-6.4e on the party or attorney designated in the subpoena a written objection to inspecting copying testing or sam5.7p-2.2ling any or all the m5.7a-2terials 7or to inspecting the premises?or to producing electronically stored inf8.3o-2rm5.9ation in the or requested The objection be served the earlier the tim5.8e specif8.2ied com5.8p-2.1liance or days af8.2ter the subpoena is served an objection is the f8.4o-1.9llowing rules apply i At any tim6e on notice to the com6m6a-1.8nded person the serving party m5.8ove the court the district where com5.8p-2.1liance is required an order com6.6p-1.3elling production or inspection ii These acts be required only as directed in the order and the order protect a person who is neither a party nor a party?s signif8.7i2.7cant expense resulting com6.3p-1.6liance or Modifyin4.8g a A When Required On tim5.4ely the cour5.3t the district where com5.9p-2liance is required quash or a subpoena that i to allow a reasonable time to comply ii requires a person to beyond the geographical lim6.1its specif7.8ied in Rule i requires disclosure privileged or other protected no exception or waiver applies or iv subjects a person to undue burden When Permitted To protect a person subject5.8 to or af8.2f8.2ected by a subpoena the court the district where com6p-1.9liance is required on quash or the subpoena if8 it requires i disclosing a trade secret or other conf8.5idential research developm6.1ent or commercial inf7.3o-3rmation or ii disclosing an unretained expert?s opinion or inf8.3o-2rm5.9ation that does not describe specif8.1ic occurrences in 10.4dispute and results the expert?s study that was not requested by a party Specifying Conditions as an Alternative In the circum6.5stances described in Rule the court instead quashing or a subpoena order appearance or production under specif9.2ied conditions the serving party i shows a substantial need the testim5.8ony or m5.8a-2terial that cannot be otherwise without undue hardship and ii ensures that the subpoenaed pers-11.8on will be reasonably com6p-1.9ensated Duties in Responding to a Subpoena Producing Documents or Electronically Stored Information These procedures apply to producing docum6.3ents or electronically stored inf7.9o-2.4rmation A Documents A person responding to a subpoena to produce docum6.5ents produce them5.6 as they are kept the ordinary course of8 business or organize and label them6.1 to correspond to the categories in the Form for Producing Electronically Stored Information Not Specified a subpoena does not specif8.4y a producing electronically stored inf8.2o-2.1rm5.8ation the person responding produce it in a or in which it is ordinarily main-6.1tained or in a reasonably usable or Electronically Stored Information Produced in Only One Form The person responding need not produce the electronically stored inf7.3o-3rmation in more than one Inaccessible Electronically Stored Information The person responding need not provide discovery electronically stored inf8.4o-1.9rm6ation sources that the person identifies as not reasonably accessible because undue burden or cost On to discovery or a protective order the person responding show that the inf8.3o-2rm5.9ation is not reasonably accessible because undue bur5.8den or cost that showing is the court nonetheless order discovery such sources the requesting party shows good cause considering the lim6itations Rule The court specif8.4y conditions the discovery Claiming Privilege or Protection A Information Withheld A person withholding subpoenaed inf8.6o-1.7rm6.2ation under a claim5.7 that it is privileged or subj7.4ect to protection as trial-preparation mu-4.8st i expressly the claim5.4 and ii describe the nature the withheld docum5.8ents com5.8m5.8unications or tangible things in a that without revealing inf8o-2.3rm5.6ation itself privileged or protected will enable-8.2 the parties to assess the claim Information Produced inf8.1o-2.2rm5.7ation produced in response to a subpoena is subject to a claim5.8 privilege or protection as trial-preparation material the person m6a-1.8king the claim6 notif8.4y any party that received the inf8.1o-2.2rm5.7ation the and the basis it Af8.1ter being notif8.2ied a party prom5.8ptly return sequester or destroy the specif8.2i-.2ed inf8.1o-2.2rm5.7ation and any copies it has not use or disclose the inf8.1o-2.2rm5.7ation until the claim is resolved-5.3 must take reasonable 5.6steps to retrieve the inf8.2o-2.1rmation the party disclosed it being notif8.2ied and prom5.8ptly present the inf8o-2.3rm5.6ation under seal the court the district where com6.1p-1.8liance is required a determ6.1i-.2nation the claim6.1 The person who produced the inf7.9o-2.4rmation must preserve the inf7.9o-2.4rmation until the claim is resolved Contempt The court the district where com5.8p-3.2liance is required?and also af8.2ter a motion is transf8.3erred the issuing court?m5.9ay hold in contem5.9pt a person who having been served without adequate excuse to obey the subpoena or an order related to it For access to subpoena m18.4a.2terials see Fed Civ a Com)18.4m18.4ittee Note Case Document Filed Page of Jeffrey Epstein5.3 EXHIBIT A DEFINITI-6.8ONS Wherever th5.7ey hereafter appear the follo wing words and phrases have the following m8.9eanings Agent shall m8.4ean any agent em8.4ployee officer director attorney independent contractor or any other person ac ting or purporting to act at the discretion of or on behalf of another Correspond5.7ence or co5.7mmunicatio5.7n sh all all written or verbal communications by any and all m8.4e-.6thods includ ing without lim8itation letters m8e-5.9m8o.2randa and/or electronic by which inform8.3ation in whatever form is stored,5.6 transm8.4itted or received and includes every m8.2a-.8nner or m8.2eans of disclosure transfer or exchange and every disclosure transfer or exchange of infor-6.8m8ation whether orally or by Docum8e-1nt or otherwise face-to-face,5.5 by telephon5.5e telecopies text transm8.5ission com8.5puter gen5.7e-.5rated m8.2e-.8ssage personal delivery or otherwise Plaintiff in the above captioned action sh all m7.8ean the plaintiff Virginia Giuffre for-6.9m7.9erly known as Virginia Roberts Defendant in the abov5.4e captioned acti on shall m8.3ean the defendant Ghislaine Maxwell an5.9d her em8.7ployees rep5.9r-1.1es5.1entatives agents.5.9 Docum8.8ent shall m8.8ean all wr4itten a nd graphic m8.2a-.8tter however produced or reproduced and each an5.6d every from8.4 whic-5.6h inform8.4ation can be pro5.6cessed transcribed transm8.6itted resto5.8r-1.2ed or m8.6e-.4moriali zed in any way by any m8.4eans regard5.6less technology or form8.2 It includes without lim8.2itation correspondence m8.2e-5.8moranda notes notations diaries papers books accounts newspa per and m8.1a-.9gazine articles advertisem8.1ents photographs videos notebooks ledger letters telegram8s cables telex m8.3e-.7ssages facsim8.3iles Case Document Filed Page of Jeffrey Epstein5.3 EXHIBIT A contracts of8.5fers agreem8.3ents reports objects ta ngible things work pape rs transcripts m8.1i-1.9nutes reports and recordings telephone or other conv ersations or communicati ons or of interviews or conferences or of other m8eetings occurr ences or transactions affidavits statem8.1ents summaries opinions tests experi m8e-1nts analysis evaluations ournals balance sheets incom8.1e-.9 statem8.2ents statistical records desk cale ndars appointm7.9e-1.1nt books lists tabulations sound recordings data processing input or output m8.1i-1.9crofilm8.1s checks statem8.3ents receipts summaries com8.3puter printouts computer pr ogram8.3s-.3 text m8.3e-.7ssages inform8.6ation kept in com8.6puter hard drives other com8.1puter drives of a ny kind computer tape back-up CD-ROM other com8.2puter disks of any kind teletypes telecopies invoices worksheets printed m8.4a-.6tter of every kind and description graphic and oral records and repr esentations of any kind and electronic writings and reco5.6rdin5.6gs as set forth in the Federal Rules of Evidence including but not lim8.9ited to o6.1r-.9igin6.1als c4.9opies where origin6.1als not available Any Docum7.8e-1.2nt with any such as initials comm7.8ents or notations of a ny kind of not deem8.1ed to be identical with one without such and is produced as a separate Docum8.4e-.6nt W9.5h.6ere there is any question about whether a tangible item8.7 otherwise described in these requests fa lls within the definition of Docum8.5ent such tang5.7ible item8.4 shall be produced Em8.3p.5loyee includes a or offi cer director agent or servan5.7t including any atto5.7rney5.7 associate partner or paralegal Including m8.4eans including without lim8.4itation Jeffrey Epstein includ5.5es Jeffrey Epstei and any entities owned or controlled by Jeffrey Epstein any em8ployee agent attorney cons ultant or representative of Jeffrey Epstein Case Document Filed Page of Jeffrey Epstein5.3 EXHIBIT A Ghislaine Maxwell includes Ghislain Maxwell and any entities owned or contro5.9lled Ghislain5.9e Maxwell any em7.9ployee agent attorney consultant or representative of Ghislain6e Person includes natural persons pr oprietorships governm8.2e-.8ntal agencies corporations partnerships trusts joint ventures groups associati ons organizations or any other legal business entity.5.6 You or Your hereinafter m8eans Jeffrey Epstein and any employee agent atto5.9rney co5.9nsultan5.9t-1.3 re4.7lated en5.9tities or other representative Jeffrey Epstein INSTRUCTIONS Production of Docum8.4e-.6nts and item8.4s requested he rein shall be at the offices of Boies Schiller Flexner LLP East Las Ol as Boulevard Suite Fort Lauderdale Florida no later than five days before the date noticed for Your deposition or if an alternate date is agreed upon no later than five days before the agreed-upon date Unless indicated otherwise the Relevant Pe riod for this Request is from8.2 to the present A Docum8.3e-.7nt should be co nsidered to be within the releva nt if it refers or rela4.7tes to co5.9mmunicatio5.9ns m8.7eetings or other events or Docum8.2e-.8nts that occurred or were created within that tim8e fra-6m8e regardless of the date of creation of the responsive Docum8e-1nt This Request calls for the production of all responsive Docum8.3e-.7nts in Your possession custody or control without regard to the physical location of such Docum7.9e-1.1nts If any Docum8.2e-.8nt requested was in Y7.6our posse ssion or control but is no longer in its possession or control state what disposition was of said Docum8.4e-.6nt the reason for such disposition and the date of such disposition.5.4 Case Document Filed Page of Jeffrey Epstein5.3 EXHIBIT A For the purposes of reading interpreting or construing the scope of these requests the term8.3s used shall be given their expans ive and inclusive interpre tation This includes without lim8itation the following a Wherever appropriate herein the si ngular form8 of a word shall be interpreted as plur al and vice versa And as well as5 shall onstrued either di sjunctively conjunctively as neces4.6sary to bring within the scope hereof any inform8.2ation as defined herein which m8i-2ght otherwise be construed to be-6 outside the scope of th is discovery request Any shall be understood to include and encompass all and vice versa Wherever appropriate herein the sculine form of a word shall be interpreted as and vice versa Including shall m8.4ean inc luding without lim7.8itation If You are unable to answer or respond fu lly to any Docum8.1e-5.9nt request answer or respond to the extent possible and specify the reasons for Your inab ility to answer or respond in full If the recipient has no Docu responsive to a particular Request the recipient shall so state.5.6 Unless ins4.8t-1.6ructed oth5.6e-.6rwise each R7.6e-.6quest shall be constru5.6e-.6d5.6 independen5.6tly and no5.6t by reference to any other Request for the purpose of lim7.9itation The words relate relating relates or any other derivative thereof as used herein includes concerning referr ing to responding to relating pertaining to connected with com7.8p0rising m7.8e-6.2morializing evidencing comme nting on regarding discussing showing describ5.7i-1.5ng reflecting an5.7alyzing constitu5.7ting.5.7 Identify means with respect to any person or any refe rence to the identity of any person to provide the addr ess telephone num8.4b.6er business business Case Document Filed Page of Jeffrey Epstein5.3 EXHIBIT A address bus5iness teleph5.8one num8.6ber addr ess and a descrip5.4tion of each such person?s connection with the events in question Identify means with resp ect to any Docum8.4ent or any reference to stating the identification of any Docum8.2en provide the title and date of each such Docum8.3e-.7nt the and address of the party or part ies responsible fo5.2r the prepara tion of each such Document the and address of the party who requested or required the preparati on and on whose behalf it was prepared the and address of the recip5.6i3.4en or recip5.7i3.5ents to each such Document and th5.7e present location of any and all of each su ch Docum8.3e-.7nt and the and addresses of all persons who5.5 have custod5.5y or contro5.5l of each such5.6 Docum8.4e-.6nt or copies thereof In producing Docum8.1e-.9nts if the original of any Docum8e-1nt cannot be located a copy shall be produced in lieu thereof and shall be legible and bound or staple in the manner as the Any copy of a Docum8.4e-.6nt that is not identical shall be considered a separate Docum8.6e-.4nt If any requested Document cannot be produ ced in full produ5.5ce the to the extent po5.1ssible specifying each reas4.3on for Your inability to p5.8r-1.2oduce th5.8e rem8.6a-.3inder of the Docum8e-1nt stating whatever inform8ation knowledge or belief which You have concerning the portion not produced If any Docum7.9e-1.1nt requested was at any one tim9.1e in exis5.5tence but are no longer in existence th5.5en so state s4.7p.5ecifying for each Docu a the type of Docum)8.6e-.4nt the types of inform8.2ation contained thereon the date upon which it ceased to exist the circum)7.9stances under which it ceased to exist the iden tity of all person ha ving knowledge of the Case Document Filed Page of Jeffrey Epstein5.3 EXHIBIT A circum8.3stances under which it ceased to exist and the identity of all persons having knowledge or who had knowledge of the contents thereof and each ind5.2i3vidual?s All Docum8.2e-5.8nts shall be produced in the order as they are kept or m8.3a-.7intained by You in the ordinary course of business You are requested to produce all drafts and notes whether typed handwritten or otherwise or prepared in connection with the requested Docum8e-1nts whether or not used Docum8.3e-.7nts attached to each ot her shall not be separated Docum8.1e-.9nts shall be produced in such fashi on as to identify the departm7.8e-6.1nt branch or office in whose possession they were located an where ap5.6plicab5.6le th5.6e natural person in whose possession they were found and business add5.4r-1.6ess of each Docum8.2e-.8nt?s custodian5.4 If any Docum8.1e-.9nt responsive to the request is withheld in all or part based upon any claim8 of privilege or protection wh ether based on statute or otherw ise state separately for each Docum8.3e-.7nt in addition to any other infor-6.5m8.3ation re quested6.4 the spec)5.2if4.4ic request which calls for the production the nature of the privilege claim8.4e-.6d its da te the and address of each name and addres4.5s of each of the addresses and/or individual to whom8.7 the Docum8.1e-.9nt was distributed if any the title position its author type of tangible object e.g letter telegram8.6 chart report recording disk etc its title and subjec4.9t m8.9a-.1tter withou6.1t r4.1e-.1vealing the inf4.1o1.1rm8.9ation as to which the priv5.8ilege is claim8.6e-.4d i with suf4f4i-1.2cient sp6ecif4i-1.2city to the Court to dete5.4rm9.4ination to whether th5.9e claim8.7 of privilege is valid each and ev ery fact or basis on which You claim8.7 such privilege and whether the Docum8.5e-.5nt contained an attachm8e-1nt and to the extent You are claim8.4i-1.6ng a privilege as to the a separate log entr address4.9i-1.5ng5.7 that Case Document Filed Page of Jeffrey Epstein5.3 EXHIBIT A If any Docum8e-1nt requested herein is withhe ld in all or part based on a claim8.5 that such Document cons4.6titu5.4tes attorney work product provid5.4e-.8 all of the inform8.2ation described in Instruction No and also identify the litigation in connection with which the Docum8e-1nt and the inf4.2o1.2rm9ation it con6.2t-1ains obtained and/or prepared Plaintiff does not seek and does not requi re the p5.6r-1.4oduction of m8.4u.6ltiple co5.6pies of identical Do5.4cum8.2e-.8nts This Request is deem8ed to be continuing If after producing these Documents You obtain or aware of any further info rm8.4ation Docum8.4e-5.6nts things or inform8.4ation responsive to this Request You are required to so state by supplem8enting Your responses and producing such additional Docum8.2e-.8nts to Plaintiff Case Document Filed Page of Jeffrey Epstein5.3 EXHIBIT A DOCUMENTS TO BE PRODUCED P-4.9URS-4.5UANT TO THIS SUB-3.7P.1OENA All video tapes audio tape photographs including film8 nega-6tives or film slides CD?s or any other print or electronic m8e-1dia depi cting You in the presence of Virginia Roberts Virg5.9inia or Ghisla)4.7ine4.7 Maxwell.5.9 All video tapes audio tape photographs including film8 nega-6tives or film slides CD?s or any other print or electronic m8e-1dia depicting Virginia Roberts All video tapes audio tape photographs including film8 nega-6tives or film slides CD?s or any other print or electronic m8e-1dia depicting Ghislaine Maxwell All video tapes audio tape photographs including film8 nega-6tives or film slides CD?s or any other print or electronic m8e-1dia depicting fem8.3a-.7les under the age of or purporting to be under the age of including pornographi whether comm ercial or amateur All Docum8.4e-5.6nts or other includi ng photographs describing or depicting nude or partially nude fem8.1a-.9les in Your possess ion including but not lim ited to all Docum8.9e-.1nts or other m8e-1dia describing or depicting how su ch photographs were disp layed in Your various residen6.2ces.6.2 All Docum8e-6nts relating to Virginia Roberts All Docum8.4e-5.6nts re4.4lating to Ghislain5.6e Maxw ell in6.2cluding a5ll Docum9e0nts rela5ted to communications with G7.7h.5islaine Maxwell from8.1 present All Docum8.2e-5.8nts relating to any m8.2e-5.8mbers of Ghislaine Maxwell?s fam8.1ily including all Docum8e-1nts related to communications with a4.5ny Ghislain5.7e Maxwell?s4.9 from8.8 present All Docum8e-6nts related to communications with Alan Dershowitz from7.7 present.6.2 Case Document Filed Page of Jeffrey Epstein5.3 EXHIBIT A All Docum8e-6nts relating to and all m8e-1dia depicting any of the following individuals present Emmy Taylor Eva Dubin Glen Dubin Alan Dershowitz Jean Luc Brunel Sarah Kellen a/k/a Sara Kensingt on and Sarah Vickers Na dia Marcinkova a/k/a Nadia Marcinko Nadia Bjorlin or any under the age of All Docum8.1e-5.9nts relating to any agreem8.1ents including by not lim8.1ited to conf4.1identia4.9lity agre4.9em8.9ents indem8.9n1.1if4.1ication agre em8.4ents agreem8.4ents or agreem8.4ents to pay f3.8ees betwee)4.6n You Ghislaine Maxwe4.6ll whether agreem8.1ents are written verbal or m8.3e-.7rely understood am8.3ong the parties and not otherwise expressed whether or not such agreem8.6ents were ever ex5.8ecuted carried All Docum8.2e-5.8nts relating to any credit cards paid for by You that were used by Ghislain5.7e M4.9a-.5xwell any related entity5.7 or Virginia Giuffre from)8.5 present.5.7 All telephone records associ ated with You including cell phone records from7.9 present that show any communications with Ghislaine Maxwell All Docum8.1e-5.9nts relating to calendars sc hedules or appointm8.2e-.8nts for You from8.2 present that relate to visits with or co mm7.8unications with Ghislaine Maxwell and under the age of All Docum7.9e-6.1nts identifying any individuals who provided You a m7.9a-1.1ssage All Docum8.1e-5.9nts identifying any individuals who You paid for sexual acts either with You or with other individuals All Docum8.7e-5.3nts iden5.9tif3.9ying any re4.7cru5.9ited5.9 by Ghislain5.9e Maxwell either work sexual acts or companionship You All Docum8e-6nts relating to any fe-6m8a-1les Ghislaine Maxwell introduced to You All Docum7.9e-6.1nts relating to any You paid to perform8 any kind of service Case Document Filed Page of Jeffrey Epstein5.3 EXHIBIT A including but not lim8.1ited to work as an assistan a m8.3a-.7ssage therapist sex worker or com8.3p.5anion All Docum8.1e-5.9nts relating to Your travel from8.1 the period of present when that was either with Ghislain5.6e Maxwell or another female or to Ghislaine Maxwell or other fem8a-1les including but not lim8ited to co mmercial flights helicopters passport records records indicating passengers traveling with ou hotel records and credit card receipts All Docum8.1e-5.9nts relating to paym8.1ents ou m8a-1de whether as 7.5cash stock 7.5real estate or in-kind to Ghislaine Maxwell or any related entity to Ghisla ine Maxwell including the TerraMar Project.5.4 All Docum8e-6nts identifying any individuals to whom8.7 Virginia Roberts pro5.9v.9ided a m8.4a-.6ssage Case Document Filed Page of
