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10 wae cle/ Ls ales) 20 21 22 23) 24 25 Case 1:15-cv-07433-LAP Document 1332-2 Filed 01/08/24 Page 7 of 42 XGAQGIUc SEALED frustrated because it's not my job to prove we're entitled to the documents. We served valid discovery requests. It's Epstein's attorney's job to show that he has a valid privilege. That's our first point. As you know, our second point is we have 49 specifically identified questions that we think he has no basis for asserting a Fifth Amendment privilege to. Ten of those questions relate to Professor Dershowitz. And the reason we are obviously entitled, in our view, to answers to those questions is he was deposed in 2010, and this was a case that he initiated. So the defense attorney said, "Do you know Mr. Dershowitz?" "Yeah, he's a friend of mine. He's my attorney." He has waived privilege over Dershowitz-related questions, at least in the ambit of that answer. So, obviously, in our view, questions 23 through 31 are no-brainers because he's waived privilege over that, and I'm not sure they have ever really responded to that. With regard to the other questions, some of these are pretty straightforward: Do you know the defendant in this case, Ms. Maxwell? I mean, you know, they lived together for ten years, and he's asserting a Fifth Amendment privilege over that? Without going into the substance of any communication you've had, you've communicated with Maxwell in the last year. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300