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Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 10 of 19 The remaining document requests are specifically targeted to obtain impeachment evidence concerning Ms. Ransome’s story, as told in the Jane Doe 43 Complaint and her affidavit submitted in support of Plaintiffs Letter Motion to Re-open Discovery in this case. There is nothing harassing about these requests for production. They seek relevant information concerning Plaintiffs claims and allegations against Ghislaine Maxwell, Jeffrey Epstein, Natalya Malyshovy, Sarah Kellen, and Nadia Marcincova, and documents that would show that the claims are not true, particularly as they relate to Ms. Maxwell: 3. All Documents that reference, relate to, or mention, whether by name or otherwise, the following individuals: Virginia Roberts, Ghislaine Maxwell, Jeffrey Epstein, Natalya Malyshov, Sarah Kellen, and Nadia Marcincova. (Complaint §{]33-58) 4. All Communications You have had in whatever form with any other female who you ever witnessed at or in a property, home, business, plane or automobile other vehicle owned or controlled by Jeffrey Epstein. 5. All Communications You have had with Natalya Malyshov, Virginia Roberts, Ghislaine Maxwell, Jeffrey Epstein, Sarah Kellen, or Nadia Marcincova. 6. Any photographs containing any image of Virginia Roberts, Ghislaine Maxwell, Jeffrey Epstein, Natalya Malyshov, Sarah Kellen, or Nadia Marcincova. 7. Any photographs taken by You, or containing any image of You, at, in or near any home, business, private vehicle (including airplane), or any other property owned or controlled by Jeffrey Epstein. 8. Any photographs that depict any home, business, private vehicle (including airplane), or any other property owned or controlled by Jeffrey Epstein. 9. All of Your passports, travel visas, or permissions to live, work or study in a foreign country, related to the years 2005-present. 10. All Communications regarding any of Your passports, visas, visa applications, or other permission to live, work or study in a foreign country, for the years 2005-present. 11. All Documents referencing any commercial plane tickets, boarding passes, or any other mode of travel during the time period 2006-2007.