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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 31 of 43 38. 39. 40, 41, 42. 43. 44. 45. 46. 47. 48. 49, Q. It would not be burdensome for you to search for any of these documents [requested in the deposition subpoena]. would it? (/d. at 228.) Q. I want to direct your attention to the item 13, which requests all -- .. .celephone records associated with you, including cell phone records, from 1999 to present that show[] communications with Maxwell, Ghislaine Maxwell, You've taken no steps to secure those documents, right? (Jd. at 229.) Q. You have seen Ms. Maxwell commit crimes, right? (Jd. at 231.) Q. When Rodriguez was describing Maxwell's involvement with underage girls, your attorneys had an interest in attacking that testimony, right? (/d. at 254.) Q. In fact, Maxwell has been a partner with you in several of your business enterprises, right? (Jd. at 264.) Q. You hope that Maxwell prevails in this litigation, right? (/d. at 265.) Q. In fact, you and your attorney actually got together on the phone with Virginia in about 2007, right? (Jd. al 269-70.) Q. Which of your attorneys was on the phone with Virginia in about 2007? (/d. at 270.) Q. This litigation will affect the reputation of associates of yours, won't it? (/d. at 333.) Q. In fact, as a pragmatic matter, you are essentially a Defendant in this action, right? (Jd. at 335,) Q. Please describe the way yours and Maxwell's business affairs are intertwined currently. (/d. at 338.) Q. What is your arrangement with Ms, Maxwell with regard to paying any - - - judgment that might be reached against her in this case? (Jd. at 370.) It is up to Epstein to show that each of these questions that he refused to answer posed a substantial risk of self-incrimination. Moreover, if Epstein can provide even some information in answer to the question without incriminating himself, he must provide that partial answer, See, e.g., Nat'l Day Laborer Org. Network v. U.S. Immigration & Customs Enf't Agency, 811 F. Supp. 2d 713, 740 (S.D.N.Y. 2011), amended on reconsideration (Aug. 8, 2011) (discussing 21