COMPOSITE EXHIBIT File Under Seal Case Document Filed Page of Case Document Filed Page of Case SEALED Document Entered on FLSD_Q_Qcket of I LE V1rg1 i Giutfre Plamnff Jeffrey r.pstl!in Defendant JRJ6 United ates District Court Southern Di trict of Florida n.vf.r l:f:.f ST Cl _1 Case No Lmkrlyiug Case No WS Sot11hem District of NLw York Sweet PLAINTIFFS ALED AGIH TO COMPIIL Tll lRODllCTLO Jl0C11ME FFRF:Y EPSTEl DER SEAL nst;AliT TO LOCAL RULE AND MOTION TO PLACE JF TIRE in the Sot1lhern District of New YcJrk the cw Y0rh cas1 The cuse concerns a dc1amation a lion broughl by a child victim of conv1ctcJ pedophile Jcffrc Epslem against his IJve-in girlfriend who a stste h.1m in prm.:urmg 1inckragc girls in luJ1ng the plaintiff Ms niuffrc 13cc:Gtw,c of Epstein t:cntral role in the New York ca it is nnportant for Ms Giuffr1 to have the requested documents frnm lum in Case Document Filed Page of Virginia Giuffre PJaintiff Jeffrey Epstein Defendant United States District Court Southern District of Florida Case No Underlying Case No Southern District of New York Sweet I PLAINTIFFS SEALED AGREED MOTION TO FILE MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS AND TESMO FROM JEFFREY EP TEJN NDER SEAL PURSUANT TO LOCAL RULE AND MOTION TO PLACE THE ENTIRE Case Document Filed Page of During his deposition pstein failed lo answer questions or produce documents in response to a Rule subpoena in the New York case The instant motion seeks to compel production from Epstein in three areas detailed more fully in the Motion to Compel based on his improper invocation of tl1e Fi.fth Amendment in refusing to comply with the subpoena Epstein invocation of the fifth Amendment was invalid for several reasons as discussed in detail in ihe Motion to Compel One of those reasons however goes to the instant request to file the motion to compel under seal and to place the docket under seal ln sbouJd be noted that the entire deposition of Epstein is confidential having been placed under the confidentiality order that exists in the case LEGAL A RGUME l11e parties agree this case should be placed under seal because of the need for confidentiality There is no va id invocation of the Fifth Amendment when there is no threat to self-incrimination and there can be no threat to self-incrimination i the government is not aware of the information Ms Giuffre seeks pursuant to her valid Rule subpoena Because Ms Giuffre seeks LO have all of the relevant proceedings to her motion to compel including the mo lion itself be placed under seal at this time the Government will not be aware of Epsteins disclosure of materials much Jess be in position to even file a motion to attempt alter the protective order In such circumstances Epstein faces no real and substantial hazard ufhis act of producing documents to Ms Giuffres counsel incriminating himself See United States Kowalik Sn S.D Fla ajjd 11th Cir andajj F.3d 11th Cir Accordingly by placing this ase under seal this Court can grani Ms Giuffre motio11 to compel and direct Epstein to produce the relevant do ttmcnts over his Case Document Filed Page of improper Fifth Amendment objections because there is no risk of rimin a tion because thc:se proceedings will be tmder seal Moreover under the Protective Order issued by the ew York case Ms Gjuffre counsel and t:ounsel for Ms Maxwell the DefendanL in the New York case are forbidden to disclose the materials for any purpose except the preparation and trial of this case Protective Order Under the terms of the protective order all materials secured in the case will be destroyed at the end of he case Protecti Order And while tl1e Protective Order does not bar the use of confidentiaJ materials at trial Protective Order i i Ms Giuffres cotmsel repre ent that they will not use at trial any documents that Epstein produces without first notifying Epstein and seeking leave Court to do so As a result Epstein can provide documents to Ms Giuffre allowing her to investigate this case without compromising any interest that Epstein may have in avoiding self-incrimination Additionally the entire deposition has already been designated as confidential by defendant Maxwell making thes proceedings subject a protective order See Motion to Compel at Addendum A copy of protective order To enforce that previously-entered confidentiality order from the Southern District of New York these proceedings should be confidenlia1 as well v-lorcover in sucb circumstances here is no substantial risk of incrimination from the mere production of documents to Ms Giuffrcs counsel who are subject to the protective order See generally Marc Youngelson The Use of26 Protective Orders Pleading the Fiflh Without Siifjering Adverse Consequences Ann Surv Am also Palmieri Slate ofNew York 2d 2d Cir Tl may be relevant to note that defendant Maxwell has not sought any documents from Epstein and thus the only issue presented here is the extent to which Ms Giuffre can use the documents Case Document Filed Page of Federal Rule of Ci vii Procedure authorizes a court for good cause to enter a protective order to seal or to limit disclosure Indeed courts have the discretion to place entire cases w1der seal See e.g Beaches MLS Inc Miami Association ofRealtor inc WL I at S.D.Fla Mana granting motion to file under seal and seaUng the case Local Rule provides the procedure to follow when a part,y seeks to file something under seal the party mw;t file a motion setting forth a reasonable basis for deparLing from the general policy of a public filing and courts in thi district routinely grant parties motions to file under seal for good cause See e.g Shire Development LLC Watson Pharmaceuticals Inc F.Supp.2d S.D.F la Middlebrooks Air Turbine Technology Inc Atlas Copco AB WL at S.D.Fla Marra Ms Giuffre has arriculated good cause to grant her motion to 1le under seaJ and to seal this case as it would facilitate the execution of a valid Rule subpoena issued upon Jeffrey Epstein an follow the confidentiality order previously entered in this case by the U.S District Comt for the Southern District of New York Counsel for Ms Giuffre has conferr wiih counsel for Epstein and counsel for Epstein has agreed to the filing of the Motion to Compel under seal I CONCLUSIO For the reasons set forth above plaintiff Virginia Gi tiff re respectfully requests that the Court grant ber Agreed Motion to file her Motion to Compel the Production of Documents and Testimony from Jeffrey Epstein under Seal Pursuan to Local Rule and Motion lo Plaue the Entfre Docket Under Seal for the reasons set forth above Dated September Respectfully Submitted Case Document Filed Page of LLP Boies Schiller Fle ner LLP Las Olas Blvd Suite Ft Lat1derdale FL David Boi Boies chiller Flexner LLP Main treet Armonk NY Br adley Edwards FARM JAFFE WEI TNG EDWAR FTSTO LEHR A orth Andrews Avenue uite Fort Lauderdale Florida I Case Document Filed Page of CERT I.FICA TE SER VICE HEREBY CERTIFY that on the 20th day of September served the foregoing document this day on the individuals identified below via email Laura A Menninger Es Jeffrey Pagliuca sq HADDON MORGA FOREMAN P.C East th A venue Denver Colorado Tel Fa Email 1menninger hmflaw.com jpagliuc ala hmfla com l.f i ll his/uin Muxwell ack Alan Goldberger Atterbury Goldberger Weiss P.A Australian Avenue South West Palm Beach FL I fax jgo dberger a ag.v,pa.c Counsel for Jeffre Epstein ii Case Document Filed Page of JS Rev FLSD Revised CML COVER MONROE BROWARD _ti PA BEACH MARTIN ST LUOE I AN A.MR OKEECHOBEE IO L.ANDS II BASl OF JlJRISDICTIO Plat ln.e 01tly Fcdolnl Qucstiou US t//ll!OYl/11/CI Nil tt Po rt HT CTZEr SHIP OF PRINCIPAL PARTIES la i X"m01r tforllolnl iv 1w ily I nl um One lJox i,r De/ando11I Go1 umtnonl PloimiJT PTF DEF lTli Ol!F Ch,zcn orrho rc I l;iJ lnuoivardled ur lrincipal Place ofUusincss Th is State Gov rm ent Defendant Diversity dlc1c 11zcmMf 11/lnrtiu 11cm Ill 17.tll of Anot hcrSl lc lneo1nm 1ed Principal Pl8 1oc Business Iu Another S1e os Ci izen or S11bjcol of a ifii1 Coiinl-ry Foreign Nat on IV NATURE OF SUT lace on htalf ltOn/y C0l RACT l0R1 l"O RrCI nrtm/PJ Drug Ko oted So!zun ln.,.,ranco 120Ma,inc Miller Act I Ncgot io n.,trumcnt DI Recovery ofOve1ymonr Enforc me1 or Judg,ne,u Mcd i euit Ac1 I Rocovc,y of Defonhcd S1udont Loon cl V.:1eru11s Reuove,y olOvcq,n nunr ofVclemn Benefits I GO Stockl1olders Suits Other Co ntract Cu1 Product Liability Franchi RE PROP C:RTV IU L,ml Cu11 le1 una11on Fore iosure Rcn1 Lense l::joctmem Tons lo La11d rrnso AL INJURY AilJ lnne DJ Alrplo11c Pmduct Liability As.au Libel Slandc Fedor Emp oyers Linbi lity Manne Mn1inc Produc1 inbn I 1y Mo or Vdh ic le Morar Vehicle Product L1uliilily Other Personn Inju ry PetSonnl lnjl Med pra ioe CIVJl IIU l!I Other Civil Rights Vot i ng Employment Housing Acco,mnad ntions PERSO Al INJURY Personal liijwy Product Lia bi lity llen 1b Core Pbannaceuticnl lcrsuna I nj my Pnxl1 ct Linbility Asbes os I nj11ry Prodi,ct Linb ili ty lE:RSON PROPERn Other Fraud iru tli hi Lcodi og Otber Personal Pmpony a mngc Propcny Damn Prodll Liabi ity PR ISO ER PllT1TION Hnbell.i Corr Alien Dc1 a1 SJO Mo ti ons Vncnte Se ntence Other of P,opcity USC 1hc LAIIOR JO Fn Lnbor StMtlards Act Lauor/Mi lntions Rnilwny Lahar Ac I a mily and Mcdicnl Leove Act Otltor L:l Lit i gation lmp Re Inc Sec1 rlly Act Tori P,oJuct Liability All Other Ro41 Property Amer w/Disnbili ies Gcncn IMMIGR IJOJ ORIGI Orisinol Procee din Emp loyme nt Ame w!Disnbillties Other Educi,tion la ce an in I Box OnM Rem ov ed Re-filed from Staie Co urt below Doatlt Pcaahy MM nmus Orhcr Civ il Rights Prison Conrliti on Civil Detaiu"c onditions of Coui iue,nent NoturnHzn ion ApplfoRl!Oll Other hnmigratiu11 Actiom Rei tcd Reopened Trnnsfcrrcd from auolhcr distriot rpM/f,1 Mn lridis tri cl Litigatio11 Transfer NKRl PTC OTlsR ST TUT I Appeal USC I SS Folse Aoc Vitndrnwn Q11i Tom USC USC a Swc Re11pp0rtiontqom PROl i,llr lUG Ant1tmsr Copyrights Bank and Sankiul 830P:itent Commerce Trnilomurk Deporlati011 Rockctoor lnllurne nnd OCIAL SBCl i R/TY Com1rn Organizati011 HIA IJ95f1 Cons u,n ur Credit Bluck Luns Cnble/Snt DIWC/D WW Scrnr1tfcs/Comu1odirle SSID Title XVI Exchnnge RS I Other Stn!UtOtv AC!ion Aijricu rural Ac E:11vi tJ1U1101ol Metters Freedom of nlbnt101i un rl!.0CJUI fAX Sll lfS Act Ta,cs U.S Plaint iff Arbitmtio11 or Dcfendunt Adminismnive Pt.OOodttre JRS n,ird Porty Act/Re or Appenl of use Ageucy cliion Cous1it1ttionnlity of S1 1e Statute Appcoltu Di,irict Judgi from Mnw,1rn Jud rnoo RcmAn from Multi distri ct Appel ute Co1 iti 5i i le VI RELATED RE-FILED CASE See ins tru ions a filed ase oY BS oN JUOGE Ke1eth A Marra a ted Cnse i;i E.S NO TRIAL.via days estimmed i both sidts lo lry en ir case VI REQU ESTE IN COl 1.PLAL CHECK JFT IS A CUSS A TION EMANDS UNDER MlOVE JNFOR lJ TTO JS TRUE CORRECT TO THE 1rnsr OP IH KNOWLEDG OAT Septemb er Ol flI ll SI ONL RECE ANIOUNT IFP JUDGE CHECK YES onl if clcmandcd in complaint IUR OEM Yes MAGJUOGI Case Document Filed Page of Case SEALED Document Entered on FLSD Docket Page of United States District Courl Southern Disttict of lorida Virginia Git1ffrc SH:.:VFN JRI CL.em IJ f;IST CT I A FT LAUD Plaintiff Case No nd rlyjng Case No WS Southern Dis1;t of New York Sweet J1 they Cpstcin Defendant I Pl.Al TTFFS SF:ALF:D IOTCO TO C0 1PEL TIIE ROOUCTIO OF DO lJMC::NTS A TESTIMO FROM JEFJl1lF.Y EPSTEIN Pla1tilf Virginia Giuffre by and through hi.::r und rsigm tl counsel rcsp1..:ctf1.1Jly submits this motion to compel lcflh:y Ep tcin to produce do urncnts and testimony in rc,;ponse to his rL 267pcat im-ornti1 or the Filth Amendment at i recent deposition This motion s1.:eks to compt:l proJuction from pstcin in thn.:c a!1:as 17irsl at his dt.:position 3p tein asserted th.it the FiHh Amendment allowld him to decline to p1oducr any documc:nts Vhatsolvcr Epstein has the burden cif demun..,traling th applicnbi I ity of tht Filih AmL"ndme nt privikge und he cannot carry hfl burden I le shoukl be 1rqui1ed to produce tlocument or at lhl vcr least a privikgi log so th,tl the Cot11t and opposing counsel can as,;ess the alid,t of his aims St:lonJ Fpstcin MIS uskc.:d apprO rna tl!y hundrnd substantive questions at his dcpos1t1on Hnd he ro 1i 1he Fifth rather than answe t:n single Ul or thi.:m otl11.:r than th quc:stion about us 11arnc Sume of the qlli:stwns he refused to ru1swcr po1-e no sub 1:1ntial risk oJ Case Document Filed Page of Virginia Giuffre Plaintiff United States District Court Southern District of Florida Case No Underly i ng Case No WS Southern District ofNew York Sweet Jeffrey Epstein Defendanl __ PLAINTIFFS SEALED MOTIO TO COMPEL THE PRODUCTION OF DOC UME TS TESTIMONY FROM JEFFREY EP TEIN Plaintiff Virginia Giuffre by and th ough her undersigned counsel respectfully submits this motion to compel Jeffrey pstein to prodllce documents and testimony in response to his repeated in ocations of the Fifth Amendment at his recent deposition This motion seeks to compel production from Epstein in three areas First at his deposition Epstein asse11ed that the Fifth Amendment a ll owed him to decline to produce any documents wh a tsoever Epstein has the burden of demonstrating the applicabilit of the Fifth Amendment privi ege and he cannot carry that burden He should be required to produce documents or at the very least a privilege log so that the Court and opposing counsel can assess the alidit of his claims Second Epstein was asked approximately hundred substantive questions at bis deposition and he took the i.fU rather than answer even a single one of them other than the question about his name Some of the questions refused to answer pose no substantial risk of Case Document Filed Page of incrimination He should be ordered to answer these peci.fic que 267tions which are enumerated in Section II be ow Third Epstein also look the Fillh when asked questions about Ghislau1e Maxwell interactions with females overseas Maxwell was Epsteins live-in girlfriend who assisted him in procuring ttnderage girls The Supreme Court bas made clear that a Fifth Arnendme11t privilege cannot be asserted with respect to incrimination in a foreign crime And certainly Epstein has no Fifth Amendment privilege involving sex crimes committed by another person Epstein should be ordered to m1swer specific question identified in Section Ill below about Maxwell actions it1 fon:ign wuntries FACTUAL BACKGROUND Ms Giuffre has iled a defamation action in the South rn District ew York against Ghislaine Maxwell In brief Ms Giuffre alleges that defendant Ms Ghislaine Maxwell defamed her by calling her a liar for filing documents alleging that Maxwell and her boyfriend Jeffrey Epstein had sexually abused her and trafficked he1 for sexu a purposes See McCawle Deel Exhibit complaint in Giuffi Maxwell As discovery in this case has proceeded Defendant initially suggested she would take Lhe Fifth and refuse to answer questions During her deposition however Defendant did not ake the fifth Instead she test ified that she suffered from a series of memory lapses and could not recall many of the key issues in dispute u1 thi case For example at her deposition Defendant indicated that she lacked recolJection of or was otherwise unable to specifically answer the fa 1J owing questi ans Whether Defendant observed a female under the age of at Jeffrey Epsteins home in Palm Beach See Mccawley Deel Ex Maxwell Depo at Maxwell has designated the entire contents ofber deposition as confidential pursuant to the Protective Order entered in that case and therefore the contents nrnst be filed under seal Case Document Filed Page of Whet11er Defendant had meet Ms Giuffre and introduced her to Epstein at Whether massage therapists at Epsteins mansions performed sexual acts Id at Vhetber Defendant wac ever present to view Ms Giuffre ma 267saging Epstein Id at Whether Defendant could reoalJ Ms Giuffre staying at any of Epstein six homes id at Whether Defendant remembered taking a trip with Ms Giuffre to travel over to Europe including London Id at Whether Defendant ever flew on one of Epsteins planes with a year old Id at Whether the notation GM on ilighl logs for passengers on Epstein planes represented the Defendant i GhLsl aine Maxwell Id at Whether Defendant could recall ever being on a flight on one of Epstein planes with Ms Giuffre id at Whether Defendant could explain why a minor would be ca!Ling Epstein to say tlrny had a female for him Id at Whether Defendant was aware of any interstate or international transportation of women aged to for purposes of having sex with pstein where they would receive compensation id at Wbetber Defendant could recall interacting with anyone other than Ms Giuffre under lhe age of on any of Epsteins properties Id at See McCawley Deel at Exhibit As this Court is aware from another pending case Epstein is a reE:,ristered sex offender who entered into a non-prosecution agreement NP A barring his prosecution for federal crime for his sexual abuse of Ms Giuffre and multiple oth1 victims Several of Epstein sexual abuse victims have filed a suit alleging hat they were not properly notified of Case Document Filed Page of the NP and 1he associated guilty plea that Epstein entered The victims allege that Epstein se ually abused them and that the Government violated their rights under the Crime Victims Rights Act CVRA U.S by not conferring with them about the deal that the Government reached with Epstein on that sex abuse The case is cwTently pending See Jane Does United States DE S.D Fla Because of Epsteins central role in the sexual abuse of Ms Giuffi-e Ms Giuffre has long been attempting to depose hirn in i.he action Epstein who is generally regarded as having vast financial resources evaded those effo1is to be served Accordingly on May Ms Giuffre sought leave to serve Epstein by alternative means Giuffi Maxwell No DE S.D Sho1ily thereafter Epstein agreed through counsel to voluntarily appear for a deposition On August Ms Giuffre served a subpoena on Epstein through hrs counsel See McCawley Deel Exhibit Rpstein subpoena The document sought production of categories of documents dilectly linked lo L11e underlying lawsuit For example request for production RFP I sought all photographs of Epstein in the presence of either Ms Giuffre or Ms Maxwel RFP sought Epstei documents relating to Ms Giuffre RFP lought Epsteins documents i-elati.ng to Ms Maxwell The subpoena requested Epst in make the production of documents within the Southern District of Flor ida On September Epsteins le gal counse1 sent a letter to Ms Giuffres legal counsel raising various objections to production of docwnenls including a Vifth Amendment privilege See McCawley Deel Exhibit Goldberger letter Because the Jetter was sent via conventional mail counsel did not receive it until September Case Document Filed Page of On September Epstein appeared pursuant to the subpoena and was deposed See McCawley Dec Exhibit transcrjpt of Epsteins deposition The deposition took place in West Paltn Beach Florida After Epstein was sworn in he invoked his Fifth Amendment right on every single substantive question he was asked except the question asking his name He was asked approximately substantive questions by counsel for Ms Giuffre and approximately substantive questions by counsel for defendant Maxwell He did not answer a single one Counsel for Ms Giuffre attempted to confer with Eps tein counsel regarding tl1c basis for the privilege objections but Epsteins counse declined LO elaborate Epstein po Tr at With regard to the subpoena producing documents Eps tein took the Fifth rather than answer questions about whether he had substantial financial resources that could minimize any burden in re ponding to the document production request ld al With regard to producing document Epstein and his lawyers asserted a fifth Amendment privilege Did you bring any documents with you today pursuam to this subpoena A Filth MR WEINI3ERG counsel for Epstein V./e would assert the Fifth Amendment as well as the act of production for the protections against rcspondfog to that question or r,rodn ing any documents relying on the Suprnme Court decision Hubble the second circuit August 1st decision in Greenfield MR CASSELL Unde rstood Ill assume you have a standing objection based on the grounds that you just described lo all my questions with regard to this subpoena Maxwell has designated the entire contents of Epstein deposition as confidential pursuant to the Protective Order entered in that case and therefore the contents must he filed under sea Case Document Filed Page of MR GOLDBERGER Just so were clear the Fifth Amendment objection as to act of production is going to apply to everything that MR CASSELL Yeah We disagree You have fill Iiifth Amendment and act production BY MR CASSELL You have made no effort to collect any of the documents requested here ht ng TH WITNESS F1 fth Amendmen BYMR CASSELL Tn of the last three weeks you made no search at all for the categories of documents requested here right WITNESS Fifth DYMR CASSELL Where are the documents requested by these requested categories A Fifth You have not produced a privilege Jog for these items have you A Fifih It would not be burdensome for you to search for any of these documents would it THE WITNESS Fifth BY MR CASSELL lt would quite simple for youf I to run arch terms such as Virginia through your e-mail accounts right THE WITNESS Fifth BY MR CASSELL And you have plenty of money to fund any of the searches that would be required to produce these documents right Defense counsel for Ms Maxwell raised various form and f0tmdation objections to these questions which are omitted for purposes this motion which seeks to compel actions by Epstein not Maxwell Case Document Filed Page of TIIE WITh12SS Fifth id at Epstein was also asked specific questions with regard to his failure to produce certain records such as telephone records regarding his communications with Maxwell Epstein also took the Fifth rather than answer any such question Id at I Epstein was also asked various questions about Maxwells interactions with females overseas In particular he was asked about actions in England id at France i at Thailand id at Brunei id at the Czech Republic and fonner Czechoslovakia id at and other foreign coumries id at Epstein refused to answer any of these questions In latter questioning Epstein took the Firlh rather than admit that parr of his basis for asserting the Fiftb Amendment priviJege was fear of foreign prosec1.1tions Id at Ms Giuffre now files the motion to compel production or the documents pursuant to her duly-issued subpoena Under Federal Rule of Civil Procedure a party may request any person to appear for a deposition to answer questions and to produce documents with.in his possession Under Fed Ci a person wbo obj cts to production can lodge an objection At tha1 point the party seeking produclion can move for an order compelling production of the documents Fed Civ i which is the step that Ms Giuffre is now laking The motion for production of documents must be filed in the Court where production is required i.e in this Court Similarly with regard to prodnction of testimony a paity seeking discovery can move for Case Document Filed Page of an order requiring disclosure Fed Civ a I The motion must also be made in the Court where the discovery is to be taken i.e in this Court Fed Civ a A party contending that a subpoena should quashed pursuant to Rule A iv must demonstrate that compliance v.rith the subpoe na would be undul burdensome Bridgeport Nlusic inc UMG Recordings lnc VM TCF WL at S,D.N Dec In addition a party asserling that he is privileged not to produce a document has the burden of establishing that privilege See i faple Wood Pcrrtn.ers L.P Indian Harbor Ins Co r.R.D applying Florida Jaw the burden or demonstrating that a privilege applies a particular communication is on the propo11ent of the privilege Un/red States Brighi F.3d 9th Cir witness asserting Flfth Amendment privilege bea rs the burden of showing esLimony or documents are privileged While Epstein can assert a Fifth Amendment privilege in this civil ca it is not for the witness to determine whether the answers are protected it is a decision left to the sound discretion of the trial court after considering the circumstances of the case To assert the privilege there must be a 267substantial and 267real threat of incrimination and not one that is merely trifling or imaginary Taube rt State Office of Ally Gen So 3d Fla Dist Ct App citing Marchetti United States U.S State Mitrani So.3d la SthDCA other internal citations omitted After Epstein explains the basis for bis invocation and Ms Giuffre responds this Court then makes findings on a question-by-question basis See e.g Capitol Prod Corp llernon 2d 8th Cir To protect the right of both parties and assu satisfactory review the court should Case Document Filed Page of clearly state the basis on which it sustains or rejects the defendants objection to a particular question Because this case is a diversity action state law generally provides the rule of decision for substantive p1ivi ege issues See Ghiffte Maxwell DE at WL at applying New York privilege law citing Allied Irish Banks Bank of Am N.A F.R.D S.D.N.Y Because lhis Courts subject matter jurisdiction is based upon diversity state law provides the rule of decision concerning the claim of attorney cLient privilege 1n this case Epsteins inability to provide a basis for fifth Amendment invocations does not turn on peculiarities of the law of any one jurisdiction and thus authorities from various jmisdictions arc cited interchangeably ARGUMENT I EPSTEIN SHOULD BE COMPELLED TO PRODUCE THE RRQURSTRD DOCUMENTS rt i Not nduly Burden omc for Epstein to Produc th Requested Document If Epstein i shes to establish undue burdensomeness in producing documents it is his bmden to carry As recounted above however Epstein has refused to answer questions regarding undue burdensomeness See Statement of Fact at Presumably this is because his vast wealth would make it difficult from him to prove that point In any event even were Epstein to atlcmpt to sho undue burdensomeness he could not establish that any burden is undue Epstein is a central figure in this case the most central figure apart from the two parties the plaintiff and the defendant nd the defendant is feigning memory lo over many oftbe most sign i ficant events in this case including many events that involved Epstein Because of his central role in the case it is impo11ant for Ms Giuffre to have the requested documents from him No undue burden i Case Document Filed Page of ll Epstein Cannot Assert a Fifth Arncndmcnt Privilege in the Documents Themselves As reflected in the transcript quoted above pstein a serted both a Fifth Amendm nt privilege not to produce the documents as well as a fifth Amendment act-of product i on privicgc n1e act of production issues will be addressed in the next section below But Epstein Fifth Amendm nt objection i frivo ous The contents of pre-existing documents are not protected by t11e Fifth Amendment he flfth Amendment only protects a witness against testifying about certain events not producing documents already in his po ition his position psteins legal counsel refer nced two cases United States llubbell U.S and UnUed States Greenfield 3d WL 2d Cir Aug But as both of those cases make I ear a defendant does not have a Fifth Amendment privilege to refuse to produce documents as opposed to the privilege that does exist to refuse give testimony verbally The Supreme Court in Hubbell specifically noted the settled proposition that a person may be required to produce specific dol:mnents even though they contain incriminating asse11ions of fact or belief because the creation of those documents was not compelled within them aning of the rn Amendment privilege Hubbell at ciling Fishe1 United States Similarly the Second Circuit in Greenfield following the Supreme Courts lead held that the contents of the records do not implicate the Fifth Amendment F.3d WL at reviewing Fi her U.S a1 See also Braswell United Stares U.S There is no question hut that the contents of subpoenaed business records are not privileged United Stales Doe IO the party asserting the Fifth Amendment privilege has voluntarily compHed the document no compulsion is present and the contents of the documeht are not privileged Case Document Filed Page of In light of t11cse controlling authorities Epstein cannot rely on a Fi llh mendment sclf inc1imination argument to withhold the documents Epstein Cannot Assert an Act of Production Pri ilcgc to Refu to Produc the Documents to Ms Giuffre Epste in cannot demonstrate that the act of producing documents in incriminating for two separate and independent reasons First he i ll no be producing any1hing publicly or to the Government but only confidentially to Ms Giuffre a private pat1y Because any such production will be confidential a nd pursuant to a protective order Epstein faces no substantial threat of prosecution from making the disclosme Second Epstein act of production as opposed to the documents themselves is not incriminating Producing Documents Confidentially to a Private Partv Under a Protective OrdeI Does Not Create a Substannal Risk of Incrimination During his depo ition Epstein cited two cases as supporting his Fiilh Amendment invocations Uniled States Hubbell U.S and United States Greenfield F.3d WL 2d Cir Aug But as even a cursory review of the case captions in those cases makes clear both of those ca cs involved litigation in which 1.he Government was attempting to force a witness to disclose inforn1ation Lo il In Hubbell the issue was whether the Government could issue a subpoena to force a witness lo tum over documents to a grand jmy investigating criminal charg U.S at In Green.f,eld the issue was similarly whether the Government specifically the Internal Revenue Service or IRS could force a taxpayer to turn over records demonstrating possible tax evasion to i Here no such disclosure to the Government will occur if Epstein is compelled to provide answers to Ms Giuffres que tions Moreover the entire deposition has already been designated as confidentia by defendant Maxwell making the proceedings subject to a protective order See Addendum A copy of protective order In such circumstances there is no substantial risk Case Document Filed Page of of incrimination from the mere production of documents to Ms Giuffres counsel See generally Marc Youngelson The Use of Protective Orders Pleading the Ffih Withoul Sujfeling Adverse Consequences Ann Surv Am see also Palmieri State of New York F.2d 2d Cir Pmsuant to the protective order Ms Giuffre counsel and Ms Maxw ls counsel are forbidden to disclose the materials for any purpose except the preparaLion and trial of this case Protective Order Under the terms of the protective order all materials secured in the case will be destroyed at the end the case Protective Order nd wbHe the Protective Ord er does not bar the use of confidential materials at trial Protective Order Ms Giuffres counsel represent that-1.hey will no use at trial any documents that Epstein produces without first notifying Epstein and seeking leave of Court to do so As a resuH Epstein can provide documents to Ms Giuffre allowing her to investigate this case without compromising any interest that Epstein may have in avoiding self-incrimination Arnl most important because all of the relevant proceedings to this motion including this motion itseJf are under seal at this time lhe Government will not even be aware of Epstein discJosurc of materials much less be in position to even file a motion to attempt alter the protective order Tn such circumstances Epstein faces no real and su bstantiaL hazard of his act of producing docmnents to Ms Giuffre counsel incriminating himself United States Kawallk Supp S.D Fla affd Jd 11th Cir and ajjd F.3d 11th Cir pstein Mere Ac of Produt.:inu Documents Does Not lncrlminat Himself Epsteins act of producing documents to Ms Giuffres counse will not only be unknown to the Government but it 1s in any event not incriminating bears emphasizing again that It may be relevant to note that defendant Maxwell not sought any documents from Epstein and thus the only issue presented here is the extenl to which Ms Giuffre cant se the documents Case Document Filed Page of the only possible claim Epstein can raise is not thal the document he possesses are in some sense incriminating but only that the a of producing those documents is incriminating See United States Doe U.S OConnor concurring the Fifth Amendment provides absolutely no protection for the contents of private papers of any kind United Slates lu bbell U.S noting tlrnt it i a scttJcd proposition that a person may be requi red to produce specific documents even though they contain incriminating assertions or fact or belief ecause the creation of those documents was not compelled I within the meaning of the piivilege Sallah Worldwide Clearing LLC Supp 2d S.D Where documents are oluntarily prepared before tJ1ey are requested fore ample the Supreme Court hash I that such documents do not contain compelled testimonial evidence witbi the meaning of the Fifth Amendment even if the contents are incriminating The so called act of produ 267tion doctrine extends protection only to communicative elements of production spedlically where compliance with a subpoena could disclose to the Government incriminating inf01mation about the existence of the documents the witnes possession or control of the documents and the authenticity or the documents United States Greef/field WL at ciling Fi lher United SUdes U.S I Once again Epstein will not be making any act of production to the Government And in any event for many documents of the subpoenaed docttments no plausible claim of act-of procluction testimony and incrimination are possible While Ms Giuffre will espond to any effort that Epstein makes to carry his burden or establ i sh ing his privilege a few simple Under the act of production doctrine Epstein bears the burden of ho wing both that the production is incriminating and Lhe testimony is in riminating Case Document Filed Page of illustTation.s will demonstrate that Epsteins claim that he need notprodu even a single cument is vastly overbroad a Records Re.fleeting Communications with Maxwell One simple example is the request for records reflecting communications between Epstein and defendant Maxwell including eel ular telephone records See Subpoena Cell phone records which would obviously have been sent to Epstein by his carrier can be easily authenticated by peopJe other than Epstein including representatives of the carrier or others knowledgeable in cell phone records ee Sallah Supp 2d at requiring production of contra ts because any contracts could be authenticated by someone other than the person invoking the fifth Amendment As a result such records are the kind of regularly-sent business records for which act of production claims are regularly rejected See Greenfield WL at noting that large commercial financial institutions naturally wold have sent regular account statements and other disclosures to account holders citing United States Norwood F.3d 8rh Cir allowi ng production of documents 267pos sessed by the owners of financial accounts as a rnatler of course associated with specific identified accounts see AJ.atter of Grand Ju,y Subpoenus Dated Oct Nov 2d Cir the act of producing c.;opics ofthc telephone company statements and bill would not cause Doe to incrimina te himself Bank Records ef le cting Payment Another similar example i Lhe request for financial records involving payments made to defendant Maxwell See SLlbpoena if Herc again the simple act of producing the bank records involved in such payments cannot be recorded as either testimonial or incriminating This is a case where il can be hown wit reasonable purlicularity that at the time that the act of production was sought to be compelled the materials were already known of thereby Case Document Filed Page of making any testimonial aspect I of the production a for egone conclusion Sallah Worldwide Clearing LLC Supp 2d Fla quoting In re Grand Jury Subpoena Duce Tecum Dated March F.3d 11th some internal citations omitted Indeed this Court bas recently required the production of bank records over a Fifth Amendment objections See Sallah P.Supp.2d at The Fifth Amendment does not shield the witnesJ a ct of production in response to th.is request seeking monthly bank account records Moreover because the documents involve payments to one specifically identified person i Maxi,vell 1he request calls for Epstein to produce an objectively determinable UJ1iversel of documents and doesl not require him to employ the contents olhis mind to choose what documents might be responsive to the requests allah f.Sup p.2d at internal quotations omitted Photographs Depicted Nude Females Epstein also lauks any self-incdmination claim for failing to produce photographs of nude or partially nude females ee Subpoena A photograph obviously does not in olv testimony And the authentioity of photographs can be establish in different ways not involving Epstein For example if a photograph airly and accurately depicts Ms Giuffre shtl herself could authenticate the photograph Eps1ein Must at a Minimum Produc.;e a Privilel!e Lou These amplcs of documents that could be produced without ris of incrimination could be easily multjplied and Ms Giuffre by filing this motion seeks to compel Eps tein to respond to all ofher docunient requests But in considering irth Amendment issues a brnader point If Epstein possesses particular photographs that are child pornography lhen production of those particular photographs could itself be incrim inating However child pornography is narrowly defined as images of a minor engaging in sexually explicit conduct See U.S.C A Ms Giuffre is not seeking the production of any uch contraband materials from Epstein Case Document Filed Page of becomes relevant pstein does nol appear to have even bothered fir collect responsive documents before asserting a Fifth Amendment claim For exampe during his depositio Epstein took the Fifth rather than answer a ues ion about wh ther he had produced a privilege log pstein po Tr at Under the federal Rules of Civil Proecdurn Epstein is requirnd tu produce a privilege log for the communic.:ations is withholding Fed Civ A provides that a person withholding subpoena information under a claim that it is privileged must describe the nature of the withheld documents communications or tangible things in a manner hat without revealing information itselr privileged or protected will enable the parties to assess the claim Epstein should have provided this log at the time of his deposition so that he could be questioned about it certainly should produce a log immediately if be hopes to sustain his claim Th ge era rule in lhis Court i that a blanket refusal to produce records or to testify is simply insufficient to support a Fifth Amendment claim United ates rwalik Supp Fla affd Jd 11th Cir and affd F.3d th Cir Instead a witness who has been subpoenaed to produce documents must present himself with his records for questioning and as to each question and ea record elect to raise or not to rais the defense Id discussing taxpayers refusal to Tespond lo IRS summons 1n addition the Cmu-ts local rules require the production of a privilege log whenever matedals arc withheld on the basis of privilege See LocaJ This rule requires preparation of a privilege log with respect to all documents electrorncally stored information things and oral communications withheld on the basis or a claim of privilege except attorney-client communications or work product materials creat after the lawsuit Case Document Filed Page of Epstein was served with a subpoena from the District Court for the Southern District of New York That Court also requ i res production of a privilege log at the i me of any objection to a subpoena As that Comt has exp ained Both Fed i and and N.Y Civ require the submission of a pr i vilege log where a person erved with a document request subpu na objects to the producti.011 of requested docu en on the ground of privilege Rule does not exp icitly state exactly when the iv il ege og must be provided Rule is more precise qu iring tha a pe son objecting to a subpoena mus se ve either written objections or move to quash wi th in ea rl ier of the i me fixed for complia ce or fourteen days afte serv i ce and if withho in subpoenaed ma ri al on he ground of ivi ege st provi a ri vilege log I thns suggests strongly that ivilege log abse jud i cial relief must accompany any objections or mo ion to quash ut Local is even more explicit Paragraph states Where a claim of priv i lege is asserted i response to discovery or di closure other than a deposition and information is not provided on the basis of such assertion the information set forth in paragraph a above shall be furnished i writing ar the rime of the response to such dis overy dis losure unless other ise order by ihe court This eflec a modification to loca rules to specifically req ire that the privilege list be furnished at the time of the response unless othe wise ordered by the court 4s re hevron Corp Supp 2d S.D a.Od sub nom Lago Agr i Plain iffs Chevron Corp App 2d ir Epstein should at a minimum be required to produce a privi ege log for each of the que tions in the subpoena and explain the basis for his Fifth Amendmen invoca io A that point Ms Giuffre wi ll be in a pos i tion to further respond and show why his invocations are no well fou ded II EPSTEIN SHOULD BE COMPELLED TO ANS VER QUESTIONS THAT FACIALL POSE NO REAL AN SUBSTANTIAL RISK OF SELF TNCRIMINATION a??v?G?S?G A a??v?G?E?I A S?I a??v?G?E π?NgN 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XzB88?W?a Y?M?Db?T l?W Ge?GS ap?1 T1 ENG?V I z??RU?C ߝvh 2?Lzvb R?OL C?Ƕ H?sd_ a?m T-?Wz i?d E"!d g?E Bx?z VW u8?O mb qW wV b?t хv UF d?W?j Sv 4ǖQDFO hK i?C?cp 7?l?VxU Vɓ Ԫ?t??b k?J e?r?5r As yR??e ȁ?jil ib n??v h?U O?6sK qyXb⅘FCJ?Ao O??s gm?6 Ȓ?Vi?BP 3c?t?ŝ V?W GU8 lujnPA kv?i??q UDŽ?f Za i qsf??;Ɗ Yn ڴX Y??mr?Å?N o??PM Il A?sQ6 XQG uɭ M?ߝ AVW-Ap kҹ JU E?qS a?uj?i Hݹ??)s ݵ?W i?T G?ԝ a C?U0 sd??S i G?r/Q;?Z Uel cѼֆ 쿢?ժ WM Vq Y?g PX?Yt?SR.??so L??G?4ENgw U??P?o jM v.C??d l7??S?IX uɮNU d?/2yh?j HB i9籼 g?k??Dp r?U??Q?t Case Document Filed Page of Epstein also took the fifth with regard to many questions for which there was no realistic risk of self incrimination As the Eleventh Circuit has explained fthe central standard for the application rof the fifth amendment privilege against self-incrimination is whether the claimant is confronted by substantial and real and nol mereJy trifling or imaginary hazards of incrimiuarion United States Argoman-iZ 2d I 1th Cir citing Marchetti United States U.S Thus the privilege applies only in instances where the witness has reasonable cause to apprehend danger of cr i minal liability Argomani F.2d at cWng Hojfinan United States U.S only does Epstein bear the burden of establishing the validity of his privilege claim but a court must make a particularized inquiry deciding in connection with each specific area that the questioning party wishes to explore whether or the privilege is well-founded Argomaniz F.2d Ith Ck Here there are a number of questions lhat does not appear to pose any substantial and real risk of incrimination These questions include the following Is there anything inc uding any physical conditions or ailments that would prevent you from giving tnithful testimony today Id at What state do you consider yourself to be a citizen of ld at You know the Defendant in this case Ghislaine Maxwell true Id at Olhel questions of a similar nature about interactions wilh Maxwell Id at Epstein has a joint defense agreement and common interest agreement with Maxwel Id at Without going into the substance of any commurucations that you have had you have communicated with Maxwell since September 21st true Id at What mail accounts has Ma-xwell used in her communications with you Td at Case Document Filed Page of In June in open court you plcd guilty to two Florida State felonies correct Id at Other similar questions relating to the state crime to which Epstein has already p1cad guilty id at In fact at that time around Maxwell was regularly at your PaJm Beach mansion true Id at Sir isnt it true that Mas Maxwell was running your Palm Beach mansion in fand other years Id Following a break in the deposition Witham going into the substance of any communication whom did you speak to during the break ld al You have m1.ions and millions of dollars avai table to your disposal to satisfy any need for assistance in responding to discovery in this case true Id at How much money have you given Ma,xwell since Id at I Other similar questions regarding financial payments to or transactions with Maxwell Id at In the period to what kind of donation did you make to the Palm Beach Police Department or to any organization associated with the Palm Beach Police Department Id at Please describe all dinners youve ever had with Bill Clinton Id at If we wanted to 267erve you with legal pr cess in the future what would be the simplest way to do that Id at Please describe all our overseas travel in the last two years Id al It a matter of public record that you later settled that lawsuit filed against you by Ms Giuffre right Id at ir you arc unwilling to sign an unconditional waiver allowin Virginia to turn over the settlement agreement to Maxwell right id at Sir you know Harvard Law Professor now former law professor Alan Dcrshowitz Id at The tran cript enant uses the erm willing but in context the term should have been recorded by the stenographer as unwilling In either event the point remain that Epstein took the Fifth rather than answer this question Case Document Filed Page of Alan Dershowitz has sent drafts of books he was writing foJ you to review right Id at Without discussing any particular attorney client communicatio11s what was the general type oflegaJ work Dershowitz did for you Id at When did Dershowitz first become your lawyer at Has Dershowi.t ever provided you business advice a onlega nature id at Shortly after Decemher Did you authorize Dershowitz to make any public statements on your behalf Id at Was that statement to the media that Hes as outraged as I am referring to Epstein an authorized statement on your behalf by Alan Dershowitz Id at Related que stions about Dershowit zs statement to the media describing a statement made by Epstein id at In and ershowitz came to visit you in your New York mansion true id at If we focus in on the years and how many time did Dershowitz visit you in your various homes id at While you were negotiating with the U.S Attorneys Office you were also working with Assistant U.S Attorneys Me11chel and Lurie to help them secure ucrative employment when the left the office right Id at Bill Cli nton flew on your jet a number of times in ight Id at Maxwell frequent Oew a helicopter in the U.S Virgin Islands right Id al Plea se list every place you and Bill Clinton have ever been together Id at Please describe all of your interactions with the CUnton Foundation Id at Sir youve made no effort to collect any of the documents requested here in U1e subpoena for the deposition right at Case Document Filed Page of It would not be burdensome for you to search for any of these documents requested in the deposition subpoena would it Id at I want to direcr your attention to the item which requests all elephone records associated with you including cell phone records from to present that show communications with Maxwell Ghislaine Mmcwell Youve taken no steps to secure those documents rjght Id at You have seen Ms Maxwell commit crimes right Id at When Rodriguez was describing Maxwells involvemenl with underage girls your attorneys bad an interest in attacking that testimony right kl at ln fact Maxwell has been a partner with you in several of your business enterprises right id at You hope that MaxweJI prevaiJs in thi litigation right id at In fact you and your attorney actually got together the phone with Virginia in about right Id at Which of your attorneys was on the phone with Virginia in about Id at This litigation will affect the rep Lt a tion of associates of yours wont it Id at Q_ Jn fact as a pragmatic matter you are essentially a Defendant in tbis actioa right Id al Please describe the way yow and Maxwell business affairs are intertwined curreutJy Id at Wbat is your arrangement with Ms Maxwell with regard to paying any judgment that might be reached against her in this case id at It is up to Eps1ein to how tha each or these questions that he refused to answer posed a substantial risk of self-incrimination Moreover if Epstein can provide ven some information in answer to the question without incriminating himself he must provide that partial answer See Nat Day Laborer Org Networkv U.S hnmigration uswms E1tt Age ncy Supp 2d amended on reconsideraliun Aug discussing Case Document Filed Page of documents redacted to different degrees to provide information without violating privilege Jones Christopher Co Supp Kan noting that witness may make partiaJ answers an stop when he believes further comment would incriminate him A witness is not exonerated from answering merely because he declares that in so doing he would incriminate himscl his say-so does not of itself establish the hazard of incrimination Marlin-Trigona Gou/eras F.2d 7th Cir Because Epstein cannot establish the hazard of incrimination with respect to each of the questions above the Court should compel rum to answer each of these questions and permit counsel to ask reasonable follow-up questions in the same vein ILL EPSTEIN SHOULD BE COl llPELLRD TO WER QUESTIO ABOUT llAX VELLS lNVOLVEMENT WITH FEMALES I FOREIGN COUNTRIES Rpstein should also be compelled to answer questions about Ma well involvement with females in foreign cow1lries The Supreme Court has made very clear that a witness may not invoke a Fifth Amendment privilege to refuse to answer questions that pose a risk of prosecution in foreign countries United tates Balsy U.S The Court reasoned that the Fifth Amendment creates rights only against the federal government and via incorporation through the Fourteenth Amendment against state governments Id at As a resuJt any argument that the Fi flh Amendment has extra-territorial application has been foreclosed Valenzuela United States F.3d 11th Cir In light of this controlJing legal authority Ms Giuffre asked Epstein a series of very narrow and specific questions about purely foreign activities The questions began with the limitation that Epstein was to understand that the next series of questions well be dealing just with your actions in England not with any of your actions in the United States Epstein Depo Tr at Epslein was then asked a series of questions including a number of questions Case Document Filed Page of involving English females This limitation is imporlant because EpsLein may seek to invoke a Fifth Amendment privilege with regard to his trafficking of Americai1 girls into England See e.g U.S.C a But no such trafficking concerns exist with regard to females already located in England For these reasons Ms Giuffre is entitled to force Epstein to disclose even his activities with foreign females in forejgn wuntries But in this motion Ms Giuffre does not go so far Instead she moves the ourt to compel answers to a much narrower set of questions specifically Ma wells intera 267tions with females overseas in specific countries The specific questions Ms Giuffre moves to compel Epstein lo answer are I While in England in Miss Maxwell private residence you observed Ma well in the presence of English females under the age of true While in England Ms Maxwell brought you English fema es to satisfy your sexual purposes true Id Please describe how many time you have seen Max ell in private locations with girls under the age of in England Id al Ba ed on ow understanding of English criminal law you have observed Maxwell commit English criminal offenses of a sexual nature in England true Id Have you ever observed Maxwell commit a crime in England Id at Please describe for me all the crime you have seen Maxwell commit in England Id at Please describe Maxwells interactions in England with females under the age of Id at France Case Document Filed Page of Maxwell has frequently been to your apartment in Paris France true Id at Thailand You saw Ma well in the presence of Thai females under the age of in Thailand tme Id at Brunei In you J1cw to Brunei with Maxwell on your private et true Id at Are you aware or intera tion by Maxwell with women in Brunei Id at Are you aware of any int raction by Maxwell with girls under the age of in Brunei Id Please describe all the jnteractions you saw between Maxw ll and girls from Brunei in Brunei id Czech Republic/Czec/wslavakia Was Maxwell ever with you when you were in the presence of girls tmder the age of in the Czech Republic Id at Has Maxwell ever in ter acted with minor girls from the former country kno rn as Czechoslovakia Id at Other Coimtrie Please name all of the countries not including the United States where you have seen Maxwell in the presence of females who lived in Lho countries under the age of Id at Please describe for me Maxwe1l sexual interactions with females under U1e age of in foreign countries with citizens of those countries id at Jlas Maxwell ever interacted witb females under the age of in foreign countJ ies Td at Based on your understanding of the criminal laws of other countries has Maxwell ever committed a crime or a sexual nature in another country Id at Case Document Filed Page of Please describe all the crimes of a sexual nature that you understand Maxwell has committed foreign countries id at Epstein cannot claim a realistic risk of incriminating himself by discussing these specific events regarding Max-.,vell CONCLUSION For the reasons set forth above plaintil1 Virginia Giuffre respectfully requests that the Court grant her Motion to Compel and direct Je ffrey Epstein to produce the documents that he has been subpoenaed to produce or a the very least produce a privilege log for each of the categories for which documents are sought answer the specific identified questions identifi ed in Section II above and reasonable fo11ow up questions that pose no substantial and real risk of incrimination and answer specific questions about Maxwells interactions with females in other countries and reasonable follow up questions as identified in Section I above Dated September Respectfully Submitted BOIES SCHILLER FLEXNER LL By Siefid Mereilith Schultz Boies Schiller Flexner LLP Las O1as Blvd Suite Ft Lauderdale FL David Boies Boies Schiller Flexner LLP Main Street Armonk NY Bradley Edwards FARMER JAFFE WEISSING DWARDS FJSTOS LEHRMAN Norlh Andrews Avenue Suite Fort Lauderdale Florida Case Document Filed Page of CERTIFICATE OF SERVICE I IlEREBY CERTIFY that on the 20th day of eptember served he foregoing docw11ent this day on the individuals identified below via email Laura A Menninger Esq Jeffrey Pagliuca Esq HADDON MORGAN OREMAN P.C East IOLI A venue Denver Colorado Tel Fax Email lmenninger lunflaw.com pagli uca hmflaw corn Counsel/or Ghislaine faxwell Jack Alan Goldberger Atterbury Goldberger Weiss P.A Australian Avenue South West Palm Beach FL fax goldberger agwpa.com Counsel for Jeffrey Epstein Case Document Filed Page of ADDENDUM A Case Document Filed Page of Case Document Filed Page of case RWS Document Filed Page of Uniccd States District Court Southern District Of New York I Virginia Giuffre J:i in ti ff Ghislaine Maxwell Dcfend nt ROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information or info1mation which will improperly annoy embarrass or oppress any party witness or person providing discovery in this case IT IS ORDERED Th i rotective Order shall app to documents materials and information including without limitation locuments produced answers to interrogatories responses to requests for admission deposition testimony and oLher infom1ation disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure As used in this Protective Order document is defined as provided in FED.R.C1V.P a A draft or non-identical copy is a separate document within the meaning of th i term Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of Jnforrnation designared 267CONFIDENTIAL shall be information that is confidential and implicates common law and stalulory privacy interests of a plaintiff Virginia Roberts Giuffre and defendant Ghislaine MaxweJI CO JFIDENTI information shall not be disclosed or used for any purpose except the preparation and trial ofthis case CO FlDENTIAL documents materials and/or information collectively CONFIDENTIAL INFORMATION shall not without the consent of the party producing it or further Order of the Court be discJosed except that such information may be disclosed to a attorneys actively working on this case persons regularly employed or associated with the attorneys actively working on this case whose assistance is required by said attorneys in the preparation for trial at trial or at other proceedings in this case the parties expert witnesses and consultants retained in connection with this proceeding to he extent such i sclosure is necessary for preparation trial or other proceedings in this case the Court and its employees Court Per!lonnel in this case stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action deponents witnesses or potential witnesses and Case Document Filed Page of Case oc ment Fi ed Page of Case WS Document Filed Page of other persons by wrinen agreement of the parties Prior to disclos ng any CONFIDE 11AL lNFORMAON to any person listed above other than counsel rsons employed by counsel Court Personnel and stenographic reporters couns sbaJJ provide such person with a copy of this Protective Order and obtain from such person a written acknowledgment tating that he or she has read this Protective Order and a grees co be hound by its provisions All such acknowledgments shall be retained by counsel and shall be subject to in a mera review by the Court if good cause for review is demonstrated by opposing counsel Documents are designated as CONFIDENTIAL by placing or affixing on lhem in a manner rhat will not interfere with their legibility the following or other appropriate nolice CONFIDEN IAL Discovery material designated CONFID NTIAL shalJ be identified by Bates number To the extent practical the respective legend shall be placed near the Ba es number Designation of a documenl as CONFIDENTIAL INFORMA TLON shall constitute a representation that such document has been reviewed by an attorne for the designating party that there i a valid and good faith basis for such de ignation made at the time of disclosure or production to the receiving party and that disclosure of such information to persons other than those permitted access to such material wou cause a privacy harm to the des i gnating part Case Document Filed Page of Case RWS Document Filed Page of Case Document Filed Page of Whenever a deposition involves the disclosure of CO FIDE TIAL NFORMATION the deposition or portions thereof sha ll be designated as CO FIDENTIAL and shall be subject to the provisions of this Protective Order Such designatiQn shall be made on the record during the deposition whenever possible hu1 a party may designate portions of depositions as CONFIDENTIAL after transcription provided written notice of the designation i promptly given to all counsel of record within thirty days after notice by the court reporter of the completion of the transcript and until the expiration of such thirty days after notice by the court reporter of the completion of the transcript no party or counsel for any uch party may share the contents ofthe deposition outside Lhe limitations of this Protective Order I Whenever a party seeks to file any document or material conta ining CONFIDENTIAL INfOR-MA TION with the Court in th is matter it shall be accompanied by a Motion to Seal ptu-suant to Section of the lectronic Case Fjling Rules Instructions for the Southern District of New York A pa1ty may object to the designation of particular CONF1DENTIAL JNFORMATTON by giving written notice to the paiiy designating the disputed information The written notice shall identify the information to which the objection is made If tht parties canm,t resolve the objection within ten business days after the time the notice is received it shall be the obligation of the party designating the information as CONFIDENTIAL to file an Case Document Filed Page of Case Document ile Page of Case RWS Document Fil ed Page of appropriate motion requesting that the Court determine whether the disputed information should be subject to the terms of this Protective Orde If such a motion i timely 6led the disputed information hall be treated as CONFIDENTIAL under he terms of this Protectiv Order until the Court rules on the motion Tf the design a tin party a ils to file such a rnotion within the prescrib ime the disput informa ion sha!l lose i ts designation a CONFIDENTIA and shall no there a fter be treated as CONFIDENTIAL in accordance wiLh this Protect i ve Order Tn connect i on with a motion filed und this provi ion the party designating the informa ion as CON IDENTTAL sh a ll bear the burden of establishing that good cause exists for the disputed i nformation to treated as CONFIDENTIAL At th conclus i on his case unle other arrangem ent are a greed upon each documen and all copies there which have been des i gnated as CONFTDENAL shall be retumed lo the party that designated it CONFIDENTIAL the panie may elect to destroy CONFIDENTIAL documents Where paiti agr to destroy CONFIDENTIAL documents he destroying party hall pro ide all parties wjth an affid av it confirming the destruc ion I This Protect i ve Order shall ha no force nd effect on the use any CO IDENTIAL INFORMA TIO a trial in this matter Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of This Protective Order may be modified by the Court at any time for good cause shown following notice to all parties and an opportunity for them to be heard
