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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 17 of 43 THE WITNESS: Fifth. Id. at 226-29 12, 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. Jd. at 229-30. 13. Epstein was also asked various questions about Maxwell’s interactions with females overseas. In particular, he was asked about actions in England (id. at 140-47), France (id. at 152-54), Thailand (id. at 154-57), Brunei (id. at 157-59), the Czech Republic (and former Czechoslovakia) (7d, at 159-63), and other foreign countries (id, at 163-64). Epstein refused to answer any of these questions. In latter questioning, Epstein took the Fifth rather than admit that part of his basis for asserting the Fifth Amendment privilege was fear of foreign prosecutions, Id. at 343. 14, Ms, Giuffre now files the motion to compel production of the documents pursuant to her duly-issued subpoena. LEGAL STANDARDS Under Federal Rule of Civil Procedure 45, a party may request any person to appear for a deposition to answer questions and to produce documents within his possession. Under Fed. R. Civ. P. 45(d)(2)(B), a person who objects to production can lodge an objection. At that point, the party seeking production can move for an order compelling production of the documents, Fed. R. Civ, P, 45(d)(2)(B)(i), which is the step that Ms. Giuffre is now taking. 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 production of testimony, a party seeking discovery can move for