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Case 1:20-cr-00330-PAE Document 731-2 Filed 07/14/22 PANTSH SHEA & The Honorable Alison J. Nathan BOYLE December 15, 2021 LLP Page 2 Ms. Maxwell would like to ask Mr. Glassman whether he made a $25 million demand to Ms. Maxwell to settle the civil case against her. It should be noted that defense counsel did not question Jane about this demand when they had a chance, so there is no impeachment value to anything Mr. Glassman could say. It should also be noted that Ms. Maxwell or Ms. Menninger (who represented Ms. Maxwell in the civil case), who are both already present in the courtroom, could testify about any such demand. So there is nothing Mr. Glassman could offer on this subject that would be probative and outweigh the risk of possible disclosure of confidential information inherent in calling Jane's attorney to the witness stand. Additionally, whether a settlement demand would have been made in the civil case against Ms. Maxwell seems wholly irrelevant as that civil case settled well over a year before Jane testified; that is, at the time Jane testified in the criminal trial, she had no financial incentive to do so. With regard to demands to the EVCP, Jane adopts the arguments made by the Government in its opposition, and adds again that the civil case settled long before Jane's testimony in the criminal trial against Ms. Maxwell — so Jane had no financial interest in the substance of her testimony. Finally, we remind the Court that we believe that the subpoena that was served on Mr. Glassman was invalid under Fed. R. Crim. Pro 17, and that Mr. Glassman is not currently under valid subpoena. Accordingly, we respectfully request that the Defendant's motion to compel Mr. Glassman to testify should be denied. DOJ-OGR-00011422