EFTA00605860

United States District Court 
Southern District of New York 
Plaintiff, 
Case No.: 15-cv-07433-RWS 
v. 
Ghislaine Maxwell, 
Defendant. 
PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF 
DOCUMENTS TO DEFENDANT GHISLAINE MAXWELL 
Plaintiff, by and through her undersigned counsel, hereby propounds Plaintiff's First 
Request for Production of Documents pursuant to Rules 26 and 34 of the Federal Rules of Civil 
Procedure to the Defendant Ghislaine Maxwell. The responses are due at the offices of Boies, 
Schiller & Flexner LLP, 401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida 
33301, within thirty (30) days of service hereof. 
DEFINITIONS 
Wherever they hereafter appear the following words and phrases have the following 
meanings: 
I. 
"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. 
2. 
"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 
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EFTA00605860

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. 
3. 
"Defendant" shall mean the defendant Ghislaine Maxwell and her employees, 
representatives or agents. 
4. 
"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, 
contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes, 
reports and recordings of telephone or other conversations or communications, or of interviews 
or conferences, or of other meetings, occurrences or transactions, affidavits, statements, 
summaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income 
statements, statistical records, desk calendars, appointment books, lists, tabulations, sound 
recordings, data processing input or output, microfilms, checks, statements, receipts, summaries, 
computer printouts, computer programs, text messages, e-mails, information kept in computer 
hard drives, other computer drives of any kind, computer tape back-up, CD-ROM, other 
computer disks of any kind, teletypes, telecopies, invoices, worksheets, printed matter of every 
kind and description, graphic and oral records and representations of any kind, and electronic 
"writings" and "recordings" as set forth in the Federal Rules of Evidence, including but not 
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limited to, originals or copies where originals are not available. Any document with any marks 
such as initials, comments or notations of any kind of not deemed to be identical with one 
without such marks and is produced as a separate document. Where there is any question about 
whether a tangible item otherwise described in these requests falls within the definition of 
"document" such tangible item shall be produced. 
5. 
"Employee" includes a past or present officer, director, agent or servant, including 
any attorney (associate or partner) or paralegal. 
6. 
"Including" means including without limitations. 
7. 
"Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or controlled by 
Jeffrey Epstein, any employee, agent, attorney, consultant, or representative of Jeffrey Epstein. 
8. 
"Person(s)" includes natural persons, proprietorships, governmental agencies, 
corporations, partnerships, trusts, joint ventures, groups, associations, organizations or any other 
legal or business entity. 
9. 
"You" or "Your" hereinafter means Ghislaine Maxwell and any employee, agent, 
attorney, consultant, related entities or other representative of Ghislaine Maxwell. 
INSTRUCTIONS 
1. 
Unless indicated otherwise, the Relevant Period for this Request is from July 
1999 to the present. A Document should be considered to be within the relevant time frame if it 
refers or relates to communications, meetings or other events or documents that occurred or were 
created within that time frame, regardless of the date of creation of the responsive Document. 
2. 
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. 
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EFTA00605862

3. 
If any Document requested was in any defendant's possession or control, but is no 
longer in its possession or control, state what disposition was made of said Document, the reason 
for such disposition, and the date of such disposition. 
4. 
For the purposes of reading, interpreting, or construing the scope of these 
requests, the terms used shall be given their most expansive and inclusive interpretation. This 
includes, without limitation the following: 
a) 
Wherever appropriate herein, the singular form of a word shall be 
interpreted as plural and vice versa. 
b) 
"And" as well as "or" shall be construed either disjunctively or 
conjunctively as necessary to bring within the scope hereof any 
information (as defined herein) which might otherwise be construed to be 
outside the scope of this discovery request. 
c) 
"Any" shall be understood to include and encompass "all" and vice versa. 
d) 
Wherever appropriate herein, the masculine form of a word shall be 
interpreted as feminine and vice versa. 
e) 
"Including" shall mean "including without limitation." 
5. 
If you are unable to answer or respond fully to any document request, answer or 
respond to the extent possible and specify the reasons for your inability to answer or respond in 
full. If the recipient has no documents responsive to a particular Request, the recipient shall so 
state. 
6. 
Unless instructed otherwise, each Request shall be construed independently and 
not by reference to any other Request for the purpose of limitation. 
7. 
The words "relate," "relating," "relates," or any other derivative thereof, as used 
herein includes concerning, referring to, responding to, relating to, pertaining to, connected with, 
comprising, memorializing, evidencing, commenting on, regarding, discussing, showing, 
describing, reflecting, analyzing or constituting. 
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8. 
"Identify" means, with respect to any "person," or any reference to the "identity" 
of any "person," to provide the name, home address, telephone number, business name, business 
address, business telephone number and a description of each such person's connection with the 
events in question. 
9. 
"Identify" means, with respect to any "document," or any reference to stating the 
"identification" of any "document," provide the title and date of each such document, the name 
and address of the party or parties responsible for the preparation of each such document, the 
name and address of the party who requested or required the preparation and on whose behalf it 
was prepared, the name and address of the recipient or recipients to each such document and the 
present location of any and all copies of each such document, and the names and addresses of all 
persons who have custody or control of each such document or copies thereof. 
10. 
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. 
11. 
document. 
12. 
If any requested Document cannot be produced in full, produce the Document to 
the extent possible, specifying each reason for your inability to produce the remainder of the 
Document stating whatever information. knowledge or belief which you have concerning the 
portion not produced. 
13. 
If any Document requested was at any one time in existence but are no longer in 
existence, then so state, specifying for each Document (a) the type of document; (b) the types of 
information contained thereon; (c) the date upon which it ceased to exist; (d) the circumstances 
Any copy of a Document that is not identical shall be considered a separate 
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EFTA00605864

under which it ceased to exist; (e) the identity of all person having knowledge of the 
circumstances under which it ceased to exist; and (f) the identity of all persons having 
knowledge or who had knowledge of the contents thereof and each individual's address. 
14. 
All Documents shall be produced in the same order as they are kept or maintained 
by you in the ordinary course of business. 
15. 
You are requested to produce all drafts and notes, whether typed, handwritten or 
otherwise, made or prepared in connection with the requested Documents, whether or not used. 
16. 
Documents attached to each other shall not be separated. 
17. 
Documents shall be produced in such fashion as to identify the department, 
branch or office in whose possession they were located and, where applicable, the natural person 
in whose possession they were found, and business address of each Document's custodian(s). 
18. 
If any Document responsive to the request is withheld, in all or part, based upon 
any claim of privilege or protection, whether based on statute or otherwise, state separately for 
each Document, in addition to any other information requested: (a) the specific request which 
calls for the production; (b) the nature of the privilege claimed; (c) its date; (d) the name and 
address of each author; (e) the name and address of each of the addresses and/or individual to 
whom the Document was distributed, if any; (f) the title (or position) of its author; (g) type of 
tangible object, e.g., letter, memorandum, telegram, chart, report, recording, disk, etc.; (h) its title 
and subject matter (without revealing the information as to which the privilege is claimed); (i) 
with sufficient specificity to permit the Court to make full determination as to whether the claim 
of privilege is valid, each and every fact or basis on which you claim such privilege; and (j) 
whether the document contained an attachment and to the extent you are claiming a privilege as 
to the attachment, a separate log entry addressing that privilege claim. 
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EFTA00605865

19. 
If any Document requested herein is withheld, in all or part, based on a claim that 
such Document constitutes attorney work product, provide all of the information described in 
Instruction No. 19 and also identify the litigation in connection with which the Document and the 
information it contains was obtained and/or prepared. 
20. 
Plaintiff does not seek and does not require the production of multiple copies of 
identical Documents. 
21. 
This Request is deemed to be continuing. If, after producing these Documents, 
you obtain or become aware of any further information, Documents, things, or information 
responsive to this Request, you are required to so state by supplementing your responses and 
producing such additional Documents to Plaintiff. 
DOCUMENTS REQUESTED 
DOCUMENT REQUEST NO. 1 
All documents relating to communications with Jeffrey Epstein from 1999 — present. 
DOCUMENT REOUEST NO. 2 
All documents relating to communications with 
from 1999 — present. 
DOCUMENT REQUEST NO. 3 
All documents relating to communications with Andrew Albert Christian Edward, Duke of York 
(a.k.a. Prince Andrew) from 1999 — present. 
DOCUMENT REQUEST NO. 4 
All documents relating to communications between you and Jeffrey Epstein regarding any 
female under the age of 18 from the period of 1999 — present. 
DOCUMENT REQUEST NO. 5 
All documents relating to massages, including but not limited to any documents reflecting 
recruiting or hiring masseuses, advertising for masseuses, flyers created for distribution at high 
schools or colleges, and records reflecting e-mails or calls to individuals relating to massages. 
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EFTA00605866

DOCUMENT REOUEST NO. 6 
All documents relating to communications with any of the following individuals from 1999 —
resent: Emmy Taylor, 
Eva Dubin, Glen Dubin, Jean Luc Brunel, and 
DOCUMENT REQUEST NO. 7 
All video tapes, audio tapes, photographs or any other print or electronic media relating to 
females under the age of 18 from the period of 1999 — present. 
DOCUMENT REQUEST NO. 8 
All documents relating to your travel from the period of 1999 — present, including but not limited 
to, any travel on Jeffrey Epstein's planes, commercial flights, helicopters, passport records, 
records indicating passengers traveling with you, hotel records, and credit card receipts. 
DOCUMENT REOUEST NO. 9 
All documents identifying passengers, manifests, or flight plans for any helicopter or plane ever 
owned or controlled by you or Jeffrey Epstein or any associated entity from 1999 — present. 
DOCUMENT REOUEST NO. 10 
All documents relating to payments made from Jeffrey Epstein or any related entity to you from 
1999 — present, including payments for work performed, gifts, real estate purchases, living 
expenses, and payments to your charitable endeavors including the TerraMar project. 
DOCUMENT REOUEST NO. 11 
All documents relating to or describing any work you performed with Jeffrey Epstein, or any 
affiliated entity from 1999 —present. 
DOCUMENT REOUEST NO. 12 
All confidentiality agreements between you and Jeffrey Epstein or any entity to which he is 
related or involved or such agreements which are or were in your possession or control related to 
any other employee of Jeffrey Epstein, or any associated entity. 
DOCUMENT REQUEST NO. 13 
All documents from you, your attorneys or agents to any law enforcement entity, or from any 
law enforcement entity to you or any of your representatives, related to any cooperation, 
potential charge, immunity or deferred prosecution, or which relates to suspected or known 
criminal activity. 
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EFTA00605867

DOCUMENT REOUEST NO. 14 
All documents relating to travel of any female under the age of 18 from the period of 1999 —
present. 
DOCUMENT REOUEST NO. 15 
All video tapes, audio tapes, photographs or any other print or electronic media taken at a time 
when you were in Jeffrey Esptein's company or inside any of his residences or aircraft. 
DOCUMENT REOUEST NO. 16 
All computers, hard drives or copies thereof for all computers in operation between 1999 —
2002. 
DOCUMENT REOUEST NO. 17 
All documents relating to communications with you and Ross Gow from 2005 — present. 
DOCUMENT REQUEST NO. 18 
All video to es audio to s, photographs or any other print or electronic media relating to 
• 
DOCUMENT REQUEST NO. 19 
All documents relating to your deposition scheduled in the matter of Jane Doe v. Epstein, 08-
80893, United States Southern District of Florida. 
DOCUMENT REQUEST NO. 20 
All documents relating to any credit cards used that were paid for by Jeffrey Epstein or any 
related entity from 1999 — present. 
DOCUMENT REQUEST NO. 21 
All telephone records associated with you, including cell phone records from 1999 — present. 
DOCUMENT REOUEST NO. 22 
All documents relating to calendars, schedules or appointments for you from 1999 — present. 
DOCUMENT REOUEST NO. 23 
All documents relating to calendars, schedules or appointments for Jeffrey Epstein from 1999-
present. 
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EFTA00605868

DOCUMENT REOUEST NO. 24 
All documents relating to contact lists, phone lists or address books for you or Jeffrey Epstein 
from 1999 — present. 
DOCUMENT REOUEST NO. 25 
All documents relating to any hospital records for 
DOCUMENT REQUEST NO. 26 
All documents relating to any passport or license for 
DOCUMENT REOUEST NO. 27 
All documents relating to any gifts or monetary payments provided to 
by you, Jeffrey Epstein or any related entity. 
DOCUMENT REOUEST NO. 28 
All documents relating to 
Robert's employment or work as an independent contractor 
with you, Jeffrey Epstein or any related entity. 
DOCUMENT REOUEST NO. 29 
All documents identifying any individuals to whom 
provided a massage. 
DOCUMENT REOUEST NO. 30 
All documents relating to any employee lists or records associated with you, Jeffrey Epstein or 
any related entity. 
DOCUMENT REOUEST NO. 31 
All documents relating to Victoria Secret models or actresses, who were ever in the presence of 
you or Jeffrey Epstein or 
between 1999 and 2005. 
DOCUMENT REOUEST NO. 32 
All documents related to communications with or interaction with Alan Dershowitz from 1999 to 
present. 
DOCUMENT REOUEST NO. 33 
All travel records between 1999 and the present reflecting your presence in: (a) Palm Beach, 
Florida or immediately surrounding areas; (b) 9 E. 71m Street, New York, NY 10021; (c) New 
Mexico; (d) U.S. Virgin Islands; (e) any jet or aircraft owned or controlled by Jeffrey Epstein. 
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EFTA00605869

DOCUMENT REOUEST NO. 34 
All documents reflecting your ownership or control of property in London between the years 
1999 and 2002. 
DOCUMENT REOUEST NO. 35 
All documents reflecting your or Jeffrey Epstein's membership or visits to the Mar-a-Lago Club 
in Palm Beach Florida between the years 1999 and 2002. 
DOCUMENT REOUEST NO. 36 
All documents you rely upon to establish that (a) 
sworn allegations "against Ghislaine 
Maxwell are untrue." (b) the allegations have been "shown to be untrue."; and (c) 
"claims are obvious lies." 
DOCUMENT REQUEST NO. 37 
All documents reflecting communications you have had with Bill or Hillary Clinton (or persons 
acting on their behalf), including all communications regarding your attendance at Chelsea's 
Clinton's wedding ceremony in 2010. 
DOCUMENT REOUEST NO. 38 
All documents reflecting contact with you by any law enforcement or police agency, including 
any contact by the FBI, Palm Beach Police Department, or West Palm Beach Police Department. 
DOCUMENT REOUEST NO. 39 
All documents reflecting training to fly a helicopter or experience flying a helicopter, including 
any records concerning your operation of a helicopter in the U.S. Virgin Islands. 
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EFTA00605870

Dated: October 27, 2015 
By: /s/ David Boies 
David Boies 
Boies Schiller & Flexner LLP 
333 Main Street 
Armonk, NY 10504 
/s/ Sigrid McCawley 
Sigrid McCawley 
(Pro Hac Vice Pending) 
Boies Schiller & Flexner LLP 
401 E. Las Olas Blvd., Suite 1200 
Ft. Lauderdale, FL 33301 
(954) 356-0011 
Ellen Brockman 
Boies Schiller & Flexner LLP 
575 Lexington Ave 
New York, New York 10022 
(212) 446-2300 
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EFTA00605871

CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on the 27th day of October, 2015, 1 served the attached 
document PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS To DEFENDANT OHISLAINE 
MAXWELL via Email to the following counsel of record. 
Laura A. Menninger, Esq. 
HADDON, MORGAN & FOREMAN, P.C. 
150 East 10m Avenue 
Denver, Colorado 80203 
Tel: (303) 831-7364 
Fax: (303) 832-2628 
Email: [email protected] 
/s/ Sigrid S. McCawley 
Sigrid S. McCawley 
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