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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 24 of 43 illustrations will demonstrate that Epstein’s claim that he need not produce even a single document is vastly overbroad. a. Records Reflecting Communications with Maxwell One simple example is the request for records reflecting communications between Epstein and defendant Maxwell, including cellular telephone records. See Subpoena, § 7, 13. Cell phone records, which would obviously have been sent to Epstein by his carrier, can be easily authenticated by people other than Epstein — including representatives of the carrier or others knowledgeable in cell phone records, See Sallah, 855 F. Supp, 2d at 1374 (requiring production of contracts because “any contracts could be authenticated by someone other than [the person invoking the Fifth Amendment]”). As a result, such records are the kind of regularly-sent business records for which act of production claims are regularly rejected, See Greenfield, 2016 WL 4073250 at *11 (noting that “large commercial financial institutions . . . naturally would have sent regular account statements and other disclosures to account holders , . **) (citing United States v. Norwood, 420 F 3d 888, 895-96 (8 Cir. 2005) (allowing production of documents “possessed by the owners of financial accounts as a matter of course” associated with specific identified accounts)); see Matter of Grand Jury Subpoenas Dated Oct. 22, 1991, & Nov. 1, 1991, 959 F.2d 1158, 1165 (2d Cir. 1992) (“the act of producing copies of the telephone company statements and bills would not cause Doe to incriminate himself”). b. Bank Records Reflecting Payments Another similar example is the request for financial records involving payments made to defendant Maxwell. See Subpoena, 21. Here again, the simple act of producing the bank records involved in such payments cannot be recorded as either testimonial or incriminating. This is a case where it can be shown “with reasonable particularity that, at the time that the act of production was sought to be compelled, . . . the materials were already known of, thereby 14