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10 val ity} ils} 14 alls) nls) ay 18 athe) ZU) 21 2X 23 24 25 Case 1:15-cv-07433-LAP Document 1332-2 Filed 01/08/24 Page 22 of 42 21 XGAQGIUc SEALED and saying that he still eleven years later or 12 years later has a document that matches the subpoena. The Fifth Amendment protects him. He should not, respectfully, be compelled to testify to produce documents. MR. CASSELL: Let me just start at the outset by noting a point of agreement. We agree that Epstein with Maxwell traveled to Florida, New York, the Virgin Islands and elsewhere to sexually abuse children, and he remains at risk for criminal prosecution in some of those cases. So we start from the same premises that there are those crimes that are out there. MR. PAGLIUCA: Your Honor, I object to this colloquy because this is improper. Ms. Maxwell denies any of what Mr. Cassell is saying, and this is just another attempt to inject this inflammatory rhetoric into the record. So I object. MR. CASSELL: This is our complaint. I don't know that -- I am reiterating what's in our complaint and explaining how it applies to this case is inflammatory. I just want to point out that we agree with that premise. Starting from that premise, the issue that is in three narrow areas are we entitled to produce or force Epstein to produce some information. We hear from Mr. Weinberg that the 1951 Hoffman case recognizes a Fifth Amendment privilege, and of course it does. More recently -- and I don't know if this was after he POUTHERN SOUS TRI CM: REROR TERS) Pi. Go. (212) 805-0300