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Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 20 of 22 issues. And because of concern that the Defendant is concealing assets, she should also be required to reveal all significant (greater than $10,000) assets or other monetary transfers in since the beginning of January 1, 2015, as well as all transfers of assets or money outside of this Court’s jurisdiction, including transfers overseas. IV. CONCLUSION Based upon the foregoing, Ms. Giuffre respectfully requests that this Court deny Defendant’s motion for a protective order barring discovery into her financial situation. In a contemporaneously-filed motion to compel, Ms. Giuffre also respectfully requests that the Court grant a motion to compel Defendant to answer questions about her financial information. Dated: August 22, 2016. Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 20