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Case 1:15-cv-07433-LAP Document 1327-12 Filed 01/05/24 Page 3 of 11 e documents relating otherwise to Plaintiff including her hospital records (RFP 25), passport (RFP 26), monetary payments made to her (RFP 27), her employment (RFP 28), and any person to whom she gave a massage (RFP 29). Ms. Maxwell conducted a thorough search of her email systems and her devices prior to her production on February 8, 2016. All documents identified as responsive were reviewed by counsel and either produced or placed on a privilege log. The First Responses were the subject of litigation in March and April 2016. This Court limited the scope of a number of the requests (see Transcript of March 17, 2016 and Order of April 15, 2016 (Doc. # 098), and Ms. Maxwell later produced, pursuant to this Court’s Order, documents that originally had been withheld pursuant to privilege. As of April 18, Ms. Maxwell’s production of documents responsive to Plaintiff's First Request for Production of Documents was complete. Plaintiff served a Second set of Requests for Production on April 14. Those Requests primarily concerned police reports about Plaintiff's various contacts with law enforcement and how the defense was able to obtain those publicly-available documents (RFP’s 1-5, 19). The Second Requests also sought: e Joint Defense Agreements with Mr. Epstein and Mr. Dershowitz (RFPs 6, 7, 9 and 10) and communications with Mr. Dershowitz’s counsel (RFP 11); e “all documents concerning Virginia Giuffre” (RFP 12); e any contracts with or agreement for legal fees to be paid by Epstein (RFP 13-15); e documents concerning public statements made by Ms. Maxwell (RFP 17-18). Again, Ms. Maxwell and her counsel conducted a thorough search and produced any responsive non-privileged documents. To date, Ms. Maxwell has produced 1,130 pages of documents. Litigation concerning whether the searches conducted were thorough enough then ensued leading to the instant submission.