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Case 1:15-cv-07433-LAP Document 1328-28 Filed 01/05/24 Page 11 of 24 DOCUMENTS TO BE PRODUCED PURSUANT TO THIS SUBPOENA 1. All email from your server containing the term “Epstein.” 2. All documents containing the term “Epstein.” 3. All records of donations made by Jeffrey Epstein or related entities. 4. All email from your server containing the term “Giuffre.” 5. All documents containing the term “Giuffre.” 6. All email from your server containing the term “Virginia.” 7. All documents containing the term “Virginia.” 8. All email from your server containing the term “vr” or “VR.” 9. All documents containing the term “vr” or “VR.” 10. All email from your server containing the term “Dershowitz” or “dershowitz.” 11. All documents containing the term “Dershowitz” or “dershowitz.” 12. All email from your server containing the term “jeevacation.” 13. All documents containing the term “jeevacation.” 14. All email from your server, and all other documents, relating to sex abuse. 15. All email from your server, and all other documents, relating to trafficking of any females. 16. All emails and all documents reflecting any placements of employees You have made with Jeffrey Epstein or related entities. 17. All emails and all documents reflecting any contracts You have concerning Jeffrey Epstein or related entities.