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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 12 of 43 incrimination, He should be ordered to answer these specific questions, which are enumerated in Section II, below. Third, Epstein also took the Fifth when asked questions about Ghislaine Maxwell’s interactions with females overseas, Maxwell was Epstein’s live-in girlfriend who assisted him in procuring underage girls. The Supreme Court has made clear that a Fifth Amendment privilege cannot be asserted with respect to incrimination in a foreign crime. And certainly Epstein has no Fifth Amendment privilege involving sex crimes committed by another person, Epstein should be ordered to answer specific questions identified in Section III, below about Maxwell’s actions in foreign countries, FACTUAL BACKGROUND 1 Ms. Giuffre has filed a defamation action in the Southern District of New York against Ghislaine Maxwell. In brief, Ms. Giuffre alleges that defendant Ms, Ghislaine Maxwell defamed her by calling her a “liar” for filing documents alleging that Maxwell and her boyfriend, Jeffrey Epstein, had sexually abused her and trafficked her for sexual purposes. See McCawley Decl., Exhibit 1 (complaint in Giuffre v. Maxwell). 2 As discovery in this case has proceeded, Defendant initially suggested she would take the Fifth and refuse to answer questions. During her deposition, however, Defendant did not take the Fifth. Instead, she testified that she suffered from a series of memory lapses and could not recall many of the key issues in dispute in this case. For example, at her deposition, Defendant indicated that she lacked recollection of or was otherwise unable to specifically answer the following questions:’ 7 Whether Defendant observed a female under the age of 18 at Jeffrey Epstein’s home in Palm Beach. See McCawley Decl., Ex. 2 (Maxwell Depo.) at 29; ' Maxwell has designated the entire contents of her deposition as confidential pursuant to the Protective Order entered in that case, and, therefore, the contents must be filed under seal. 2