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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 33 of 43 involving “English females.” This limitation is important because Epstein may seek to invoke a Fifth Amendment privilege with regard to his trafficking of American girls into England. See, e.g., 18 U.S.C. § 2421(a). But no such trafficking concerns exist with regard to females already located in England. For these reasons, Ms. Giuffre is entitled to force Epstein to disclose even his activities with foreign females in foreign countries, But in this motion, Ms, Giuffre does not go so far. Instead, she moves the Court to compel answers to a much narrower set of questions — specifically, Maxwell’s interactions with females overseas in specific countries. The specific questions Ms, Giuffre moves to compel Epstein to answer are: England 1. Q. While in England, in Miss Maxwell's private residence, you observed Maxwell in the presence of English females under the age of 18, true? (/d.) 2. Q. While in England, Ms, Maxwell brought you English females to satisfy your sexual purposes, true? (Ud) as Q. Please describe how many times you have seen Maxwell in private locations with girls under the age of 18 in England? (/d. at 142) 4, Q, Based on your understanding of English criminal law, you have observed Maxwell commit English criminal offenses of a sexual nature in England, true? (ld.) 5. Q. Have you ever observed Maxwell commit a crime in England? (/d, at 143.) 6. Q. Please describe for me all the crimes you have seen Maxwell commit in England. (/d. at 144.) 7, Q. Please describe Maxwell's interactions in England with females under the age of 18. (/d. at 144.) France bo LSP]