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Case 1:20-cr-00330-PAE Document 480-1 Filed 11/21/21 Page5of16 ATTACHMENT A DEFINITIONS “You” or “Your” means any owner, shareholder, partner or employee of the Epstein Victim's Compensation Program ("EVCP"), and any former owner, shareholder, partner or employee of the EVCP. . “Accusers” or “Accuser” means . Attorneys means legal counsel for any Accuser or the EVCP. “Communication” means all forms of correspondence, including regular mail, email, text message, memorandum, or other written communication of information of any kind. ‘“EVCP Material” refers to any submission to the Epstein Victim’s Compensation Program made by an Accuser, including any claims on behalf of persons who have accused Jeffrey Epstein or Ghislaine Maxwell of any misconduct, any releases signed by an Accuser or their Attorneys, and any compensation received by an Accuser. INSTRUCTIONS Production of documents and items requested herein shall be made in person to United States District Court, Southern District of New York, 40 Foley Square, New York, NY 10007, Courtroom 318. This Request calls for the production of all responsive Documents in Your possession, custody or control without regard to the physical location of such documents. If any Document was in your possession or control, but is no longer, state what disposition was made of said Document, the reason for the disposition, and the date of such disposition. In producing Documents, if the original of any Document cannot be located, a copy shall be produced in lieu thereof, and shall be legible and bound or stapled in the same manner as the original. . Any copy of a Document that is not identical shall be considered a separate document. . All Documents shall be produced in the same order as they are kept or maintained by You in the ordinary course of business. Responsive electronically stored information (ESI) shall be produced in its native form; that is, in the form in which the information was customarily created, used and stored by the native application employed by the producing party in the ordinary course of business. Defendant does not seek and does not require the production of multiple copies of identical Documents. This Request is deemed to be continuing. If, after producing these Documents, you obtain or DOJ-OGR- 00007371