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Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 17 of 24 89. 90. 91, 92. All other then-minor girls, recruited by Ghislaine Maxwell, whose identities Ms. Giuffre will attempt to determine, with whom Defendant, Ghislaine Maxwell and Jeffrey Epstein, have engaged in sexual activity. All pilots, chauffeurs, chefs, and other employees of either Defendant Maxwell or Jeffrey Epstein with knowledge of Defendant and Jeffrey Epstein’s inappropriate conduct with underage girls. All staff and employees at the Mar-a-Lago Club during 1999-2002. All other witnesses learned through discovery process. Relevant Documents: lL. 10. 11. 13. All files held by the Palm Beach Police Department or the Palm Beach State Attorney's office which are publically available. All press releases of Ghislaine Maxwell or on her behalf. The video(s) of Ghislaine Maxwell adopting the January, 2015 press statement. All newspaper or other media where Ghislaine Maxwell’s press release appears. All evidence obtained by the Federal Bureau of Investigations which relate in any way to Jeffrey Epstein or Ghislaine Maxwell. All 302 statements that relate in any way to Jeffrey Epstein or Ghislaine Maxwell. All evidence obtained by the FBI or United States Attorney’s office by or through the criminal investigation of Alfredo Rodriguez. All documents relating to the previous subpoenas served on Defendant for her deposition and all documents related in any way to that deposition. All documents evidencing visitors or passengers at any of Jeffrey Epstein owned or controlled property or aircraft, All documents demonstrating the relationship between Bill Clinton and Jeffrey Epstein or Ghislaine Maxwell. All photos of Ghislaine Maxwell at Chelsea Clinton’s wedding. All documents or information refuting statements made by Ghislaine Maxwell. All documents and information relating to Prince Andrews travel, including travel to New York City and the Caribbean, in 1999 to 2002. 16 CONFIDENTIAL