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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 25 of 43 making any testimonial aspect [of the production] a ‘foregone conclusion.*” Sallah v. Worldwide Clearing LLC, 855 F. Supp. 2d 1364, 1372 (S.D. Fla. 2012) (quoting In re Grand Jury Subpoena Duces Tecum Dated March 25, 2011, 670 F.3d 1335, 1346 (11th Cir.2012) (some internal citations omitted). Indeed, this Court has recently required the production of bank records over a Fifth Amendment objections. See Sallah, 855 F.Supp.2d at 1375 (“The Fifth Amendment does not shield [the witness’s] act of production in response to this request [seeking monthly bank account records].”). Moreover, because the documents involve payments to one specifically identified person — i,e., Maxwell —the request calls for Epstein to produce “an objectively determinable universe[] of documents and dofes] not require [him] to employ the contents of his mind to choose what documents might be responsive to the requests. Sallah, 855 F.Supp.2d at 1373 (internal quotations omitted). €. Photographs Depicted Nude Females Epstein also lacks any self-incrimination claim for failing to produce photographs of nude or partially nude females. See Subpoena, § 5.° A photograph obviously does not involve testimony. And the authenticity of photographs can be established in different ways not involving Epstein. For example, if a photograph fairly and accurately depicts Ms. Giuffre, she herself could authenticate the photograph, 33 Epstein Must, at a Minimum. Produce a Privilege Log. These examples of documents that could be produced without risk of incrimination could be easily multiplied — and Ms. Giuffre, by filing this motion, seeks to compel Epstein to respond to all 22 of her document requests, But in considering Fifth Amendment issues, a broader point ° If Epstein possesses particular photographs that are “child pornography,” then production of those particular photographs could itself be incriminating. However, child pornography is narrowly defined as images of a minor “engaging in sexually explicit conduct.” See 18 U.S.C. 2256(8)(A). Ms. Giuffre is not seeking the production of any such contraband materials from Epstein, 18