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10 dbak 12 ES) 14 als) 16 a? 18 ALS) 20 21 22 23 24 25 Case 1:15-cv-07433-LAP Document 1332-2 Filed 01/08/24 Page 10 of 42 XGAQGIUc SEALED letter from the government, I've not seen any phone calls from anyone to Mr. Epstein. There has been no showing that there's any grand jury convened. There's no summons to Mr. Epstein to appear in any criminal matter. And all we have is this unsubstantiated assertion of "I may be prosecuted somewhere for something." The law is very clear that it's Mr. Epstein's burden to establish some reasonable possibility of prosecution. That hasn't happened. And unless that happens, I believe Mr. Epstein should be forced to answer all questions put to him. . It's very difficult in my view to litigate this issue in that vacuum, your Honor, because I don't know what statute of limitations we're talking about because I don't know what crime is being proffered as what Mr. Epstein may be in jeopardy ObwEacinicn So I think that that should be the Court's order, in that there's been a failure to demonstrate any reasonable possibility of prosecution. Mr. Epstein should answer all questions. I do think it's a little difficult to piecemeal this out, your Honor, because when I listen to Mr. Cassell, he says, I want to narrowly ask questions about what did you see Mey Maxwells dow Welle think the Cour’ knoweand Me. Gasca. knows, certainly, if there were a prosecution that were SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300