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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 28 of 30 App.-0831 | GALMGIUC Your representation sounds right. MR. EDWARDS: Additionally, just with respect to the affidavit, there needs to be an affirmation that we have no other claims that relate to the statements in this case. Is that what we are saying? THE COURT: I think it should be broader than that. I Gel think it should be -- look. I don't think it would be appropriate if there is any possibility for either of you to being a party. That's what I'm after. And having any proceedings against you arising out of the situation with the plaintiff. I think it would be inappropriate for you to be counsel if you have the potentiality of being a party, either plaintiff or defendant, in any proceedings. If I get an affidavit saying that you're unaware of any claims against you or any intention to make a claim arising out of the circumstances surrounding this lawsuit, that should be broad. I think that would satisfy me. MR. EDWARDS: Ok. = MR. CASSELL: I'll be filing those materials this afternoon, your Honor. My plan is to attend -- THI! Gad COURT: The defense has a thought on this. MR. PAGLIUCA: Your Honor, I am looking at documents from Florida. One is a docket sheet captioned: Epstein v. Brad Fdwards and Paul G. Cassell, Lower Tribune Cases 15 000072 which shows that that matter is still pending. There is SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0500 DOJ-OGR-00003830