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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 14 of 43 the NPA and the associated guilty plea that Epstein entered, The victims allege that Epstein sexually abused them and that the Government violated their rights under the Crime Victims’ Rights Act (CVRA), 18 U.S.C. 3771, by not conferring with them about the deal that the Government reached with Epstein on that sex abuse. The case is currently pending. See Jane Does v. United States, No. 9:08-o-v-80736, DE 361 (S.D. Fla.). 4. Because of Epstein’s central role in the sexual abuse of Ms. Giuffre, Ms. Giuffre has long been attempting to depose him in the action. Epstein, who is generally regarded as having vast financial resources, evaded those efforts to be served. Accordingly, on May 25, 2016, Ms. Giuffre sought leave to serve Epstein by alternative means, Giuffre v. Maxwell, No. 1:15-ev-07433, DE 160 (S.D.N.Y.). Shortly thereafter, Epstein agreed through counsel to voluntarily appear for a deposition. 2 On August 25, 2016, Ms, Giuffre served a subpoena on Epstein through his counsel, See McCawley Decl., Exhibit 3 (Epstein subpoena). The document sought production of 22 categories of documents directly linked to the underlying lawsuit. Por example, request for production (“RFP”) 1 sought all photographs of Epstein in the presence of either Ms. Giuffre or Ms. Maxwell, RFP 6 sought Epstein’s documents relating to Ms, Giulfre. RFP 7 sought Epstein’s documents relating to Ms. Maxwell. The subpoena requested Epstein make the production of documents within the Southern District of Florida 6. On September 2, 2016, Epstein’s legal counsel sent a letter to Ms. Giuffre’s legal counsel raising various objections to production of documents, including a Fifth Amendment privilege, See McCawley Decl., Exhibit 4 (Goldberger letter), (Because the letter was sent via conventional mail, counsel did not receive it until September 8, 2016.)