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44) abi) 20 21 22 Px 24 ON) Case 1:15-cv-07433-LAP Document 1332-2 Filed 01/08/24 Page 18 of 42 17 XGAQGIUc SEALED subject of the Florida search warrant, that, therefore, it's a foregone conclusion that he has records in 2016. And the specific request is not all telephone records. It's all telephone records associated with you, including cell records from 1999 to the present that show any communications with Ghislaine Maxwell. So he, Mr. Epstein, has to -- to answer this paragraph, it's not just dump cell records in a document response; it's go through cell records to determine from your state of mind whether any particular record matches this subpoena request, which is a record of a communication with Ms. Maxwell. Well, in this case given the allegations made by Ms. Giuffre about Mr. Epstein and Ms. Maxwell, he's got a Fifth Amendment against even admitting that he knows Ms. Maxwell; that he's spoken to Ms. Maxwell. He has a Fifth Amendment against producing a record that he spoke to her during the time period of these allegations. Second is that there is no foregone conclusion that a record that existed in 2005 is still controlled by Mr. Epstein in 2016. And we cited to the Second Circuit's August 1 opinion that addressed just this issue, and they said, "Whether it is a foregone conclusion that documents remained in Greenfield's control through the issuance of the summons in 2013 is the issue. Only if the retention of a record that could be shown to exist many years before, only if they can show that it's still retained on the date of the subpoena is it a foregone BOUASRN Deel eno Lees) i Ged (212) 805-0300