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10 alal, aly ak3} 14 ayy 16 AL a6 AES) 20 2d: 22 23 24 25) Case 1:15-cv-07433-LAP Document 1332-2 Filed 01/08/24 Page 6 of 42 XGAQGIUc SEALED valid discovery requests. Similar points could be made -- and I know you've seen the briefing on bank records. Again, we've given you not just the theory that there are bank records. We've given you the bank. We've given you account numbers. Remember, the Palm Beach Police Department executed a search warrant and actually got some of the bank records. So, the idea that he can now assert a Fifth Amendment privilege over bank records that are in the hands of the government strikes us as, to put it mildly, farfetched. We've also asked for production of photographs. And, there again, in our exhibits filed along with the reply brief, we've actually given you photographs of the photographs we want. The existence of those photographs is a foregone conclusion. The cops went into Epstein's mansion executing a search warrant, saw photographs, and we simply want him to produce those photographs. Finally, we think we've made a compelling case for those three particular areas of documents, but at a minimum, we're entitled to a privilege log. The defendant wants to litigate, or Mr. Epstein wants to litigate, this motion to compel in the abstract, but that's not the way it's done. The local court rules, the Federal Rules of Civil Procedure, all cited in our brief, say you have to provide a privilege log if you're going to establish the privilege. Again, I'ma little SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300