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10 et, i 138 14 15 16 ey 18 a 20 21 aD. 23 24 25 Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 20 of 30 App.-0823 19 GALMGIUC review so you are aware of the ongoing investigation. But it is my view that that needs to be protected. As you probably know, the history of these cases with Mr. Epstein, there were a variety of things that went on in that investigation, so there is reason to keep an investigation in this situation protected so that they can properly investigate and move forward with that without being inhibited by other individuals. Your Honor, I would ask that that remain protected. It's covered by her very, very broad requests, which is why we had to lodge those objections. I would appreciate your Honor considering our arguments with respect to that issue. The other things, your Honor, that she has raised is, for example, she had asked for the Epstein settlement agreement and that was one of the things that she asked for. We agreed to produce that if we got the waiver from Mr. Epstein because we can't produce it without that waiver. I believe that covers it, your Honor. If you have any questions, I would be happy to answer them. THI! ll COURT: Thanks very much. Thank you all for all the clarification that you've given me. I much appreciate it. With respect to the retainers and the dates of representation, that information will be provided for any attorney that's listed on the privilege log. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0500 DOJ-OGR-00003822