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Case 1:15-cv-07433-LAP Document 1328-28 Filed 01/05/24 Page 18 of 24 To: TerraMar Project, Inc. EXHIBIT A DEFINITIONS Wherever they hereafter appear the following words and phrases have the following meanings: thi “Plaintiff” in the above captioned action shall mean the plaintiff Virginia Giuffre formerly known as Virginia Roberts. De “Defendant” in the above captioned action shall mean the defendant Ghislaine Maxwell and her employees, representatives or agents. 3, “Agent” shall mean any agent, employee, officer, director, attorney, independent contractor or any other person acting, or purporting to act, at the discretion of or on behalf of another. 4. “Correspondence” or “communication” shall mean all written or verbal communications, by any and all methods, including without limitation, letters, memoranda, and/or electronic mail, by which information, in whatever form, is stored, transmitted or received; and, includes every manner or means of disclosure, transfer or exchange, and every disclosure, transfer or exchange of information whether orally or by document or otherwise, face-to-face, by telephone, telecopies, e-mail, text, modem transmission, computer generated message, mail, personal delivery or otherwise. 35 “Document” shall mean all written and graphic matter, however produced or reproduced, and each and every thing from which information can be processed, transcribed, transmitted, restored, recorded, or memorialized in any way, by any means, regardless of technology or form. It includes, without limitation, correspondence, memoranda, notes, notations, diaries, papers, books, accounts, newspaper and magazine articles, advertisements, photographs, videos, notebooks, ledgers, letters, telegrams, cables, telex messages, facsimiles,