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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 35 of 43 19. Q, Please describe all the crimes of a sexual nature that you understand Maxwell has committed foreign countries. (/d. at 164.) 20. Q. Epstein cannot claim a realistic risk of incriminating himself by discussing these specific events regarding Maxwell. CONCLUSION For the reasons set forth above, plaintiff, Virginia Giuffre, respectfully requests that the Court grant her Motion to Compel and direct Jeffrey Epstein to: (1) produce the documents that he has been subpoenaed to produce (or, at the very least, produce a privilege log for each of the categories for which documents are sought); (2) answer the specific, identified questions identified in Section IT above (and reasonable follow up questions) that pose no substantial and real risk of incrimination; and (3) answer specific questions about Maxwell's interactions with females in other countries (and reasonable follow up questions), as identified in Section IIT above. Dated: September 20, 2016 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: Sigfid McCawl Meredith Schultz Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 25