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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 16 of 43 MR, GOLDBERGER: Just so we're clear, the Fifth Amendment objection as to actof production is going to apply to everything that -- MR. CASSELL: Yeah. We disagree. You have an lifth Amendment and act of production. BY MR. CASSELL: Q. You have made no effort to collect any of the documents requested here, right? ..3 THE WITNESS: Fifth Amendment, BY MR. CASSELL: Q. In of the last three weeks you made no search at all for the 22 categories of documents requested here, right? THE WITNESS: Fifth. BY MR. CASSELL: Q. Where are the documents requested by these 22 requested categories? A. Fifth. Q. You have not produced a privilege log for these items, have you? A. Fifth. Q. It would not be burdensome for you to search for any of these documents, would it? . .. THE WITNESS: Fifth. BY MR. CASSELL: Q. It would be quite simple for you[] to run search terms, such as Virginia. through your e-mail accounts, right? - . THE WITNESS: Fifth. BY MR, CASSELL: Q. And you have plenty of money to fund any of the searches that would be required to produce these documents, right? _ . . > Defense counsel for Ms. Maxwell raised various “form and foundation” objections to these questions, which are omitted for purposes of this motion, which seeks to compel actions by Epstein, not Maxwell.