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10 AML 1h) ar} 14 ais) al is! aly) 18 19 20 Pak 22 ZS) 24 PAS) Case 1:15-cv-07433-LAP Document 1332-2 Filed 01/08/24 Page 5 of 42 XGAQGIUc SEALED (The following was held in a sealed courtroom) MR. CASSELL: Your Honor, we would move to compel the testimony of Epstein. I know you've read the pleadings. I could just highlight a couple of small matters for you. Paul Cassell for plaintiff, Virginia Giuffre. Our motion to compel breaks down into three very narrow pieces, as you know, from the pleadings. Let me highlight a couple of things that we think are foregone conclusions in the language of the case law. Cell phone records. We've established, and, for example, in our reply brief, we have an exhibit that gives you not just general descriptions of phone records but very particular information about the phone records, even the ten digits that belong to the phone numbers. We've given you line one in Palm Beach County, line three in Palm Beach County. We've given you two phone numbers on Epstein's Gulfstream jet. We've given you two phone numbers on his 727. The existence of telephone records for those specifically identified numbers is a foregone conclusion. And with regard to authenticating them, obviously the phone company can authenticate those. So we haven't heard any argument that provides any basis for his refusal to produce those phone records. And, remember, it isn't my job to convince you. It's their job to convince you that they have a valid Fifth Amendment privilege to not answering what are obviously very SOUTHERN: DISTRICT) REPORTERS, | 2..C. (212) 805-0300