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OMANDNRWNK Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 52 of 134 J. Epstein - Confidential settlement agreement? MR. CASSELL: Yes. MR. GOLDBERGER: Okay. MR. WEINBERG: And a standing -- and a standing objection to these questions are based, if there is a confidentiality agreement, on the agreement, which is subject to confidentiality. MR. PAGLIUCA: Which I have asked for and don't have. MR. CASSELL: Right. Which is why -- well, in any event. BY MR. CASSELL: Q. Sir, you are willing to sign an unconditional waiver allowing Virginia to turn over the settlement agreement to Maxwell, right? A. Fifth. Q. Now, if we talk about the 2009 litigation between you and Maxwell, during that litigation you conveyed threats to Virginia? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. OMINDNKRWNK Page 200 J. Epstein - Confidential . Fifth. . When did you first meet Alan Dershowitz? . Fifth. . It would be fair to describe Alan Dershowitz as a good friend of yours, true? A. Fifth. Q. Please describe your relationship with Alan Dershowitz. A. Fifth. Q. Alan Dershowitz has sent drafts of books he was writing for you to review, right? A. Fifth. Q. What books of Alan Dershowitz' have you read? A. Fifth. Q. What drafts of Alan Dershowitz' have you read? A. Fifth. . Dershowitz was your lawyer as well as your friend, right? A. Fifth. Q. Without discussing any particular attorney-client communications, what was the general type of legal work he did for you? Page 199 J. Epstein - Confidential BY MR. CASSELL: Q. Indirectly you threatened Virginia with harm if she did not agree to your proposed settlement terms, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Without disclosing any amount that you ultimately paid, if any, it was your intent that your threats would reduce the amount that you would have to pay to Virginia, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please describe all the threats you've ever made to Virginia. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Sir, you know Harvard Law Professor, now former law professor, Alan Dershowitz? Page 201 J. Epstein - Confidential A. Fifth. MR. WEINBERG: Attorney-client privilege. MR. CASSELL: Attorney-client privilege? Oh, okay. BY MR. CASSELL: Q. When did Dershowitz first become your lawyer? MR. WEINBERG: Attorney-client privilege. MR. CASSELL: The date is attorney-client privilege? MR. WEINBERG: Yes. THE WITNESS: Fifth. BY MR. CASSELL: Q. Itis true, sir, that Dershowitz first became your lawyer in about 1999, right? MR. WEINBERG: Attorney-client privilege. BY MR. CASSELL: Q. Has Dershowitz ever provided business advice for you? A. Fifth. Q. Has Dershowitz ever provided you business MAGNA® 51 (Pages 198 to 201) LEGAL SERVICES