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10 akal, aly) i.) 14 AL's) IG ALy/ ils} pie! 20 ee 22 P33) 24 a5 Case 1:15-cv-07433-LAP Document 1332-2 Filed 01/08/24 Page 14 of 42 at XGAQGIUc SEALED rescission remedy is a potential remedy. He has not dismissed Mr. Cassell's arguments. Instead, he has made it very clear in this opinion that he is strongly considering them, and if the violations, even though they were government violations of the CVRA, are proven, that he is going to consider rescinding Mr. Epstein's protections. Again, those are limited protections to the Southern District of Florida, but even those are in peril as a result of the resourcefulness and arguments made by Mr. Cassell. So clearly, Mr. Epstein has a reasonable fear that if he is being asked to testify about the allegations made by Ms. Giuffre, whether it's directly or indirectly, by being asked, well, did Ms. Maxwell -- was she ever in the presence of underage women and you, the allegation is Ms. Maxwell helped Mr. Epstein have massages, erotic massages, sexual massages from underage women. Any questions, whether they're in a document request, whether they're for testimony about Ms. Maxwell, about Ms. Giuffre are squarely within heartland of the Supreme Court's 1951 eight-to-one decision Hoffman v. U.S. I learned about that in law school back a long time ago. It is still the compelling precedent. It says any testimony that could be a link in the chain of evidence that has a reasonable risk to you, you are not compelled to testify about. It talks about, yes, we're going to give up having full testimony, whether it's in grand juries or civil trials because we are going to honor SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300