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Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 19 of 45 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) rape” in reference to police reports describing incidents that took place when Ms. Giuffre was fourteen years old. (March 21, 2016, meet and confer call). Then, Defendant’s responses to Ms. Giuffre’s interrogatories shockingly called this victim of sexual abuse a “sexually permissive woman.” (Defendant’s Response to Plaintiffs First Set of Interrogatories). This last blame-the- victim contention is strange and ironic for two reasons. First, Ms. Giuffre was a minor child, not a “woman,” when Defendant sexually abused her. Second, it was Defendant and Mr. Epstein who trafficked her to other individuals - therefore, it was Defendant and Mr. Epstein’s “permission” given to others to use Ms. Giuffre’s sexually. Such language from Defendant and her counsel is wholly inappropriate. Ms. Giuffre also objects to this request because such events would have taken place in Florida, and information relating to those events is protected from disclosure by law. Florida statutes protect “[a]ny information in a videotaped statement of a minor who is alleged to be or who is a victim of sexual battery . .. which reveals that minor’s identity.” Fla. Stat. § 119.071. Additionally, Fla. Stat. 985.036 protects records where a juvenile is a victim of a crime. Further, Section 794.026, Fla. Stat., creates a civil right of action against an individual who communicates to others, identifying information concerning the victim of a sexual offense. Additionally, Second, Fla. Stat. § 985.04 and Fla. Stat. § 985.054 make juvenile law enforcement records confidential from members of the public, and states that information obtained by a law enforcement agent participating in the assessment of a juvenile is confidential. Finally, certain of the police reports implicate Ms. Giuffre’s involvement with the Florida Department of Children and Families, see e.g., GM_00750, and if such reports are part of the State’s Department of Children and Families’ records, they are confidential pursuant to Fla. Stat. § 39.202(6). Accordingly, Ms. Giuffre objects to this request for the reasons stated in this paragraph. 18