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10 ala al?) Als} 14 15 16 a7 Als! Als) 20 a 22 23 24 PMS) Case 1:15-cv-07433-LAP Document 1332-2 Filed 01/08/24 Page 12 of 42 dik XGAQGIUc SEALED Mr. Epstein has a sufficient and reasonable fear of self-incrimination were he to be compelled by court order to answer the questions that were proposed to him. The fear comes in part from proceedings in the Southern District of Florida. He pled guilty to two very narrow state offenses that dealt with two women. That gives him no protection against a federal prosecution, no protection against any other allegation, no protection against the specific allegations that are front and center in the complaint in this case, where Ms. Giuffre says that Mr. Epstein with Ms. Maxwell committed a whole universe of criminal offenses against her in places, including Florida, but also in New Mexico, in New York, in the Virgin Islands in France and England and on planes. So there is no protection from the state plea for any of the allegations made by Ms. Giuffre in this case. There is a risk that whatever limited protections Mr. Epstein has as a result of his signing and performing under a federal non-prosecution agreement he entered with the U.S. Attorney's Office in the Southern District of Florida, that protection is limited, and it's at risk. It's at risk largely because of the efforts of Mr. Cassell. And I don't mean to be critical. He is representing two other clients in this case. It's a crime victims rights case brought before District Court Marra starting in 2008. Still existing. Mr. Cassell has made it very clear he testified in a deposition in a different case SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300