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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 37 of 50 6. the form of any such Communication, whether oral or written and if written, the format of any such Communication; the identities of all persons involved in such Communication, including, the identity of the media organization with whom the agent is or was affiliated; the article title, date of publication, and means of publication of any article, report, or re-printing of any such Communication made by You or Your Attorneys; the amount of Income that You and/or Your Attorneys received in exchange for any such Communication; the dates on which You and/or Your Attorneys received any such Income for any such Communication. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as You contend in paragraph 9 of Count I of Your Complaint, including: a. b. c. d. 7. the exact false statement; the date of its publication; the publishing entity and title of any publication containing the purportedly false statement; the URL or internet address for any internet version of such publication; and the nature of the publication, whether in print, internet, broadcast or some other form of media. State whether You believe that You have ever been defamed by anyone other than Ghislaine Maxwell. If so, as to each alleged act of Defamation, state a. the exact false statement; b. c. d. 8. the date of its publication; the publishing entity and title of any publication containing the purportedly false statement; the URL or internet address for any internet version of such publication; and the nature of the publication, whether in print, internet, broadcast or some other form of media. Identify the individuals referenced in Your pleadings filed in the U.S. District Court for the Southern District of Florida, Jane Doe I and Jane Doe 2 v. United States of America, 08-cv-80736-KAM, as the “high-profile non-party individuals” to whom Mr. Jeffrey Epstein sexually trafficked You, “including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders,” including as to each episode of alleged sexual trafficking: acs. the date of any such sexual trafficking; the location of any such sexual trafficking; any witnesses to any such sexual trafficking; any Income You received in exchange for such sexual trafficking; and 31