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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 19 of 30 App.-0822 18 G4LMGIUC MS. McCAWLEY: I think we are on the same page. didal Tl COURT: I think talking about the earlier period. MS. McCAWLEY: Prior to Epstein, no, no, she doesn't have a claim with respect to that. THI! ea COURT: Anything else? MS. McCAWLEY: Your Honor, I just want to point out again that our production -- you asked us to complete that. We have gone through and run over 200 search terms. We have produced all of those communications she has had with all of those individuals. The things that we have not produced are the criminal investigation records. I know your Honor is going to address that. I would like to be very clear there. The point there is that she has said in the motion to stay papers that she filed Tuesday that she needs to have that information so she can decide whether she is going to be asserting her Fifth Amendment privilege. Truthful testimony shouldn't have to be crafted, your Honor. She shouldn't need to know what agency is investigating her in order to decide whether or not she is going to be asserting her Fifth Amendment privilege. We do have with us, your Honor, for an in camera submission, if you would like it. That is the way that courts have dealt with this issue in the past. When there is a claim from an agency that the disclosure of that investigation could harm the investigation, we can submit that to you for in camera SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0500 DOJ-OGR-00003821