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ae! ail ale} Al's} 14 Al's) all iy aN) Ake) 20 21 a2 2 24 Ze Case 1:15-cv-07433-LAP Document 1332-2 Filed 01/08/24 Page 15 of 42 14 XGAQGIUc SEALED this historic privilege. I think Mr. Cassell in a very creative way has tried to ask the Court to essentially invalidate a privilege of somebody who is at risk. In part, even in this case, Ms. Schultz's co-counsel, Ms. McCawley said when she was offering investigative records of another agency about an ongoing investigation, that's the word she used on April 21, 2016 at pages 18 and 19, and your Honor granted their right to provide your Honor in camera without disclosure whatever efforts were being made currently by Ms. Giuffre to motivate prosecutions or prosecutors against Ms. Maxwell, but the case against Ms. Maxwell is a case against Mr. Epstein. So he has a legitimate and principal concern that either the protections he has are too limited or they're going to be invalidated down in Florida. So that's the response to Ms. Maxwell's argument that he has no Fifth Amendment because he has no risk. He's at the epicenter of risk. Directing myself more specifically to Professor Cassell's arguments, the Fifth Amendment is an issue that they've briefed, we've briefed, without agreeing that there is ROVSLacucavot limits; thatettis. the Pate) of as chin, Ms. Giuffre is still a child. There is an interplay between questions that ask Mr. Epstein, was Ms. Maxwell with an underage woman. You know, were you with underage women and questions like that, whether it's Thailand or France or England, that if they relate to the travel, then certainly what SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300