LAW OFFICES OF GREGORY L POE PLLC THE EXECUTIVE BUILDING 1O3O 15TH STREET, N.W., SUITE 58O WEST WASHINGTON, D.C. 2OOO5 www.gpoelaw.com Tel: Fax: June 9, 2016 Via Email and First Class U.S. Mail Sigrid S. McCawley, Esq. Boies, Schiller & Flexner LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, FL 33301 Re: Giuffre v. Maxwell. No. 15-cv-07433-RWS (S.D.N.Y.1 Dear Ms. McCawley: This firm represents Jeffrey Epstein with respect to the enclosed subpoena duces tecum in the above-referenced matter ("Subpoena"). On May 27, 2016, Martin Weinberg (who represents Mr. Epstein in Does v. United States, No. 08-CV-80736-KAM (S.D. Fla.)) accepted service of the Subpoena subject to an agreement that the U.S. Virgin Islands would be the place of compliance and that Mr. Epstein reserves "all rights to contest the breadth of the subpoena and whether a deposition should be required at all" in light of the Fifth Amendment invocation that Mr. Weinberg has represented to you will be made in connection with the Subpoena. We write to assert and preserve all objections under Fed. R. Civ. P. 45. If you intend to proceed with the Subpoena despite the position stated on Mr. Epstein's behalf by Mr. Weinberg, Mr. Epstein continues to reserve the right to take all appropriate action with respect to the Subpoena. I. Mr. Epstein objects to the Subpoena on the ground that it places an undue burden on him. That undue burden includes, but is not limited to, the cost and inconvenience of a deposition of a non-party invoking his Fifth Amendment privilege in connection with the Subpoena where the plaintiff will not obtain, as a result of the Subpoena, information within the scope of Fed. R. Civ. P. 26(b)(1) or information (if any) that otherwise may properly be obtained or used under the rules and in the action. 2. Mr. Epstein objects to the Subpoena to the extent that it seeks or purports to require production or disclosure of privileged or other protected matter