Giuffre_Maxwell_Batch7_p00064.png

ada ala, al cls 14 alls) Mlk iy 18 als) 20 2 22 Ze 24 PX) Case 1:15-cv-07433-LAP Document 1332-2 Filed 01/08/24 Page 21 of 42 20 XGAQGIUc SEALED whether the category of documents that are asked for in this subpoena are all privileged because they all ask Mr. Epstein to supply a document related to Virginia Giuffre, provide all documents providing relating to Ms. Maxwell, provide payments to Ms. Susue (ph), provide payments through credit cards that show Ms. Maxwell and Ms. Giuffre. In other words, all of the requests that would require him to use his mind, make a selection, and produce a record that when matched against the request would be incriminating testimony. ' The cases are clear, including the Hoffman case from 1951, that you don't have to incriminate yourself, whether it's through a log or through testimony to raise the Fifth Amendment . I'll end with a quote from Judge Learned Hand that was cited in a Yale Law Journal article called, "The Conjures Dilemma," which is the Fifth Amendment in civil cases where Judge Learned Hand says, "Obviously, a witness may not be compelled to do more than show that the answer is likely to be dangerous to him, else he will be forced to disclose those very facts which the privilege protects." To do a lie, to set out pictures of Virginia Giuffre 2001, the subpoena at paragraph 19 page 6 of the subpoena wants a log by date and by the content of a document that you're raising a privilege to. That has the same perils as the production of the document. It would be Mr. Epstein going through documents, listing them, naming them SOUTHERN (DESTRICTOREPOR TERE, | Pi Cy (212) 805-0300