Giuffre_Maxwell_Batch5_p00219.png

Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 32 of 43 documents “redacted to different degrees” to provide information without violating privilege); Jones v, B. C. Christopher & Co,, 466 F, Supp. 213, 223 (D. Kan. 1979) (noting that witness “may make partial answers and stop when he believes further comment would incriminate him”). A “witness is not exonerated {rom answering merely because he declares that in so doing he would incriminate himself; his say-so does not of itself establish the hazard of incrimination.” Martin-Trigona v, Gouletas, 634 F.2d 354, 360 (7th Cir. 1980), Because Epstein cannot establish the hazard of incrimination with respect to each of the questions above, the Court should compel him to answer each of these questions (and permit counsel to ask reasonable follow-up questions in the same vein). Ill. EPSTEIN SHOULD BE COMPELLED TO ANSWER QUESTIONS ABOUT MAXWELL’S INVOLVEMENT WITH FEMALES IN FOREIGN COUNTRIES. Epstein should also be compelled to answer questions about Maxwell’s involvement with females in foreign countries. The Supreme Court has made very clear that a witness may not invoke a Fifth Amendment privilege to refuse to answer questions that pose a risk of prosecution in foreign countries. United States v. Balsys, 524 U.S. 666 (1998). The Court reasoned that the Fifth Amendment creates rights only against the federal government (and, via incorporation through the Fourteenth Amendment, against state governments). Jd, at 672-74. Asa result, any argument that the Fifth Amendment has extra-territorial application has been foreclosed. Valenzuela v. United States, 286 F.3d 1223, 1229 (11th Cir. 2002). In light of this controlling legal authority, Ms. Giuffre asked Epstein a series of very narrow and specific questions about purely foreign activities, The questions began with the limitation that Epstein was “to understand that the next series of questions we'll be dealing just with your actions in England, not with any of your actions in the United States.” Epstein Depo. Tr. at 140. Epstein was then asked a series of questions — including a number of questions 22