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Case 1:15-cv-07433-LAP Document 1320-31 Filed 01/03/24 Page 13 of 24 TO: JEAN LUC BRUNEL EXHIBIT A responsive to this Request, you are required to so state by supplementing your responses and producing such additional Documents to Plaintiff. 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 taken that relate to: (1) Alan Dershowitz; (2) Virginia Roberts; (3) Alan Dershowitz in the presence of Virginia Roberts; and (4) Alan Dershowitz in the presence of Jcfirey Epstein and and/or any female agent or employee of Jeffrey Epstein. 2 All video tapes, audio tapes, photographs, including film negatives or film slides, CD’s, or any other print or electronic media taken that relate to: (1) Ghislaine Maxwell; (2) Ghislaine Maxwell in the presence of Virginia Roberts; (3) Ghislaine Maxwell in the presence of Jeffrey Epstein and and/or any female agent or employee of Jeffrey Epstein; and (4) Ghislaine Maxwell in the presence of any female under the age of eighteen (18) years old. 3, All video tapes, audio tapes, photographs, including film negatives or film slides, CD?’s, or any other print or electronic media taken that relate to: (1) Jeffrey Epstein; (2) Jeffrey Epstein in the presence of Virginia Roberts; and (3) Jeffrey Epstein in the presence of any female under the age of eighteen (18) years old. 4. All video tapes, audio tapes, photographs, including film negatives, film slides. CD’s, or any other print or electronic media taken that relates to Emmy Taylor, Sarah Kellen, or Nadia Marcinkova. §: All documents that relate to: (1) Alan Dershowitz; (2) Virginia Roberts; (3) Alan Dershowitz in the presence of Virginia Roberts; and (4) Alan Dershowitz in the presence of Jeffrey Epstein and/or any female agent or employee of Jeffrey Epstein.