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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 22 of 43 of incrimination from the mere production of documents to Ms, Giuffre’s counsel. See generally Mare Youngelson, The Use of 26(c) Protective Orders: “Pleading the Fifth” Without Suffering “Adverse” Consequences, 1994 Ann, Sarv. Am. L. 245 (1995); see also Palmieri v. State of New York, 779 F.2d 861 (2d Cir, 1985). Pursuant to the protective order, Ms. Giuffre’s counsel (and Ms, Maxwell’s counsel") are forbidden to disclose the materials for “any purpose except the preparation and trial of this case.” Protective Order, 4, Under the terms of the protective order, all materials secured in the case will be destroyed at the end of the case. Protective Order, { 12. And while the Protective Order does not bar the use of confidential materials at trial, Protective Order § 13. Ms. Giuffre’s counsel represent that they will not use at trial any documents that Epstein produces without first notifying Epstein and seeking leave of Court to do so. As a result, Epstein can provide documents to Ms, Giuffre, allowing her to investigate this case without compromising any interest that Epstein may have in avoiding self-incrimination. And most important, because all of the relevant proceedings to this motion — including this motion itself —are under seal at this time, the Government will not even be aware of Epstein’s disclosure of materials, much less be in position to even file a motion to attempt alter the protective order, In such circumstances, Epstein faces no “real and substantial hazard” of his act of producing documents to Ms. Giuffre’s counsel incriminating himself. United States vy. Kowalik, 809 F. Supp. 1571, 1577 (S.D. Fla. 1992), aff'd, 12 F.3d 218 (11th Cir, 1993), and aff'd, 12 F.3d 218 (11th Cir. 1993), ey Epstein’s Mere Act of Producing Documents Does Not Incriminate Himself. Epstein’s act of producing documents to Ms. Giuffre’s counsel will not only be unknown to the Government, but it is, in any event, not incriminating. It bears emphasizing — again — that * Tt may be relevant to note that defendant Maxwell has not sought any documents from Epstein, and thus the only issue presented here is the extent to which Ms. Giuffre can use the documents. 12