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Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 19 of 26 Has information about Ghislaine Maxwell and Jeffrey Epstein’s sexual trafficking conduct and interaction with underage minors. 91. Doug Wilson Family member who may have knowledge of Ghislaine Maxwell and Jeffrey Epstein’s sexual trafficking conduct and interaction with underage minors. 92. Igor Zinoview Address unknown at this time Telephone number unknown at this time Has knowledge of Ghislaine Maxwell and Jeffrey Epstein’s sexual trafficking conduct and interaction with underage minors. 93. All females identified in the police reports or identified through the United State’s Attorney’s office during or through the criminal investigation of Jeffrey Epstein and his co-conspirators. 94. 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. 95. 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. 96. _—_ Allstaff and employees at the Mar-a-Lago Club during 1999-2002. 97. All other witnesses learned through discovery process. B. Relevant Documents: 1. All files held by the Palm Beach Police Department or the Palm Beach State Attorney’s office which are publically available. 2. All press releases of Ghislaine Maxwell or on her behalf 18 CONFIDENTIAL as to victims’ identity pursuant to Court’s June 23, 2016 Order