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Case 1:15-cv-07433-LAP Document 1320-31 Filed 01/03/24 Page 8 of 24 TO: JEAN LUC BRUNEL EXHIBIT A or conferences, or of other meetings, occurrences or transactions, affidavits, statements, summarics, opinions, tests, experiments, analysis. evaluations, journals, balance sheets, income statements, statistical records, desk calendars, appointment books, lists, tabulations, sound recordings, dala processing input or output, microfilms, film negatives, film slides, memory sticks, checks, statements, receipts, summaries, computer printouts, computer programs, text messages, e-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, yraphic 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. > “Employee” includes a past or present officer, director, agent or servant, including any attorney (associate or partner) or paralegal. 6. “Including” means including without limitations. Fe “Jeffrey Epstein” includes Jeffrey Epstein and any entities owned or controlled by Jefirey Epstein, any employee, agent, attorney, consultant, or representative of Jelfrey Epstein. 8. “Ghislaine Maxwell” includes Ghislaine Maxwell and any entities owned or controlled by Ghislaine Maxwell. any employee, agent, altorney, consultant. or representative of Ghislaine Maxwell.