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10 all, 12 3} 14 iS) 16 uy ae Vy) 20 21 OD 23, 24 es) Case 1:15-cv-07433-LAP Document 1332-2 Filed 01/08/24 Page 9 of 42 XGAQGIUc SEALED covered by the standard five-year statute of limitations in federal court. If you look at the elements of that crime, it involves simply traveling for sexual purposes. It's not the kind of crime that would warrant a lifetime statute of limitations. Again, that lifetime statute of limitation is reserved for very narrow offenses. So we're entitled to force him -- again, we're not trying’ to force him to testify to everything under the sun. We want him to testify to events before 2010, so that's outside the five-year statute of limitations. And we're not even asking him to testify about events concerning him. We're asking him to say, well, when you were in Thailand, did you see Maxwell in the presence of underage girls. So, we've come up with three narrowly crafted requests, and we believe we're entitled to have Epstein compelled to answer the questions in those three areas. Thank you, your Honor. MR. PAGLIUCA: Your Honor, Jeff Pagliuca on behalf of Ms. Maxwell. I have also filed a motion to compel Mr. Epstein's testimony before your Honor. I take a little bit of a different approach here, Judge, because in my view there has been no showing by Mr. Epstein that there is any reasonable possibility of criminal prosecution. I've not seen one document, I've not seen any letter from a police agency, I've not seen any target SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300