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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 11 of 43 FILED BY SEP 20 206 STEVEN fk CAAIMORE OT oy United States District Court Southern District of Florida CLEP LE THOT SD.OFRA er LAUD Virginia L. Giuffre, Plaintiff, Case No.: Underlying Case No.: 15-cv-07433-RWS (Southern District of New York) (Sweet, J.) v. Jeffrey Epstein, Defendant. PLAINTIFF’S SEALED MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS AND TESTIMONY FROM JEFFREY EPSTEIN Plaintiff Virginia Giuffre, by and through her undersigned counsel, respectfully submits this motion to compel Jeffrey Epstein to produce documents and testimony in response to his repeated invocations of the Fifth Amendment at his recent deposition. This motion seeks to compel production from Epstein in three areas. First, at his deposition, Epstein asserted that the Fifth Amendment allowed him to decline to produce any documents whatsoever. Epstein has the burden of demonstrating the applicability of the Fifth Amendment privilege, 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 validity of his claims. Second, Epstein was asked approximately 500 hundred substantive questions at his deposition, and he took the Fifth rather than answer even a single one of them (other than the question about his name). Some of the questions he refused to answer pose no substantial risk of