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Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 37 of 45 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) between the four Jane Does, via Ms. Giuffre's attorneys, would be plainly be subject to attorney client protection, not to mention work product protection as well. With regard to contact with "witnesses,” the request is vague, unduly burdensome, and overbroad. The CVRA case centers on issues surrounding whether the U.S. Government failed to confer and otherwise protect the rights of victims (including Janes Does 1, 2, 3, and 4) during plea negotiations with Jeffrey Epstein. Accordingly, some of the main "witnesses" in the case are the Government prosecutors who handled the plea negotiations. Several of the same prosecutors who handled the plea negotiations are also involved in defending the CVRA case. The CVRA has been in litigation for nearly eight years, and there have extensive communications with the prosecutors (including communications concerning approximately 10,000 pages of documents that were requested by victims’ counsel and provided to Judge Marra for in camera review). The request appears designed to target all of these communications, and such communications, going back eight years, would necessitate a review of several hundreds of thousands of emails over that time to identify communications with the Government prosecutors. The burden would be substantial and the relevance would be essentially non-existent. Whatever communications Ms. Giuffre's attorneys would have had with government prosecutors about CVRA notifications concerning a prosecution of Epstein would not shed light on whether Defendant Maxwell defames Ms. Giuffre in attacking her as, for example, a liar. Moreover, many materials related to this case remain under Judge Marra’s protective order. Accordingly, before Ms. Giuffre’s counsel could even have the option to release certain materials that the Government has provided to him as an attorney in the case, defendant Maxwell would have to approach Judge Marra and seek a modification of the protective order. 36