Giuffre_Maxwell_Batch1_p00672.png

Case 1:15-cv-07433-LAP Document 1320-31 Filed 01/03/24 Page 14 of 24 6. All documents relating to models or females that you employed who also worked for or interacted with Jeffrey Epstein or Ghislaine Maxwell. 7: All documents relating to Jeffrey Epstein from 1996 — present. 8. All documents relating to Ghislaine Maxwell from 1996 — present. 2 All documents relating to communications with any of the following individuals from 1999 — present: Emmy Taylor, Sarah Kellen and Nadia Marcinkova. 10. All video tapes, audio tapes, photographs or any other print or electronic media taken at a time when you were with Jeffrey Epstein or Ghislaine Maxwell. Uy All video tapes, audio tapes, photographs or any other print or electronic media taken at a time when you were at, or nearby, Jeffrey Epstein or Ghislaine Maxwell's residences, hotel rooms/suites. automobiles, or aircraft. 11. All documents relating to your travel from the period of 1996 — 2008, when that travel was either with Ghislaine Maxwell or Jeffrey Epstein, or to meet Ghislaine Maxwell or Jefirey Epstein, including but not limited to commercial flights, helicopters, passport records, records indicating passengers traveling with you, hotel records, and credit card receipts. 12. All documents relating to payments made from Jeffrey Epstein, Ghislaine Maxwell, or any related entity to you from 1996 — present. 13. All documents relating to or describing any work you performed with Jeflrey Epstein, Ghislaine Maxwell, or any affiliated entity from 1996 — 2008. 14. All documents relating to any credit cards used that were paid for by Jeffrey Epstein, Ghislaine Maxwell, or any related entity from 1996 — present. AS: All telephone records associated with you, including cell phone records, from 1996 — present, that show any communications with either Jeffrey Epstein or Ghislaine Maxwell.