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Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 28 of 48 e. Ron Eppinger f. _ Bill Clinton g. Stephen Hawking h. Al Gore i. Any of the individuals identified by You in response to Interrogatory No. 8 and No. 14. Response to Request No. 6 Ms. Giuffre objects to this request in that documents responsive to this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms. Giuffre’s request seeking communications between the Defendant and Ms. Giuffre and between Jeffrey Epstein and Ms. Giuffre. Subject to and without waiving the above objections, Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE005353, and will produce non-privileged documents responsive to this Request and will continue to supplement her production. Ms. Giuffre does not have “original, native format,” as requested so she is producing the paper copies she has in her possession, custody and control. 7. All photographs and video of You in any of Jeffrey Epstein’s properties, including, but not limited to: his home in Palm Beach, Florida; his home in New York City, New York; his ranch in Santa Fe, New Mexico; and Little Saint James Island in the US. Virgin Islands. To the extent You have such photographs and video in their original, native format, please produce them in that format (not a paper copy). 27