Epstein Secrets

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 • DOCUMEN

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 DEF

half of Ms. Maxwell. No further communication will be provided by her on this matter. 6 EFTA00792761 Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is o not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The origin

United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant JOINT PRETRIAL STATEMENT Pursuant to this Court's individual

half of Ms. Maxwell. No further communication will be provided by her on this matter. 6 EFTA00617401 Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is so not a new individual. The allegations made by against Ghislaine Maxwell are untrue. The original allegations a

United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant JOINT PRETRIAL STATEMENT Pursuant to this Court's individual

rized by you or authorized your agent(s) to make statements on your behalf in January of 2015. ANSWER: 2. Identify any action that you took after Ross Gow issued the January 2015 statement regarding Ms. to the public to retract or remediate the statement, clarify the statement, or otherwise cause a d

United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT GHISLA