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OMNADNARWNK Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 59 of 134 Page 226 J. Epstein - Confidential MR. PAGLIUCA: I can share. That's fine. BY MR. CASSELL: Q. Have you seen this document before today, sir? A. Fifth. Q. I want to direct your attention to page 8 of this document regarding -- you see page 8? A. Yes, sir. Q. And you see there's the heading "Documents to Be Produced Pursuant to This Subpoena"? A. Yes. Q. Did you bring any documents with you today pursuant to this subpoena? A. Fifth. MR. WEINBERG: Mr. Epstein would assert the Fifth Amendment as well as the act of production for the protections against responding to that question or producing any documents, relying on the Supreme Court decision in Hubble, the Second Circuit's August | decision in Greenfield. MR. CASSELL: Understood. And I'll assume you have a standing objection based on the OMANDNRWNKE J. Epstein - Confidential foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Where are the documents covered by these 22 requested categories? A. Fifth. Q. You have not produced any privilege log for these items, have you? A. Fifth. Q. It would not be burdensome for you to search for any of these documents, would it? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. It would be quite simple for you to run search terms, such as Virginia, through your e-mail accounts, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. And you have plenty of money to fund any of the searches that would be required to produce these Page 22 J. Epstein - Confidential grounds that you just described to all my questions with regard to this subpoena. MR. GOLDBERGER: Just so we're clear, the Fifth Amendment objection as to act of production is going to apply to everything that -- MR. CASSELL: Yeah. We disagree. But I understand you have a Fifth Amendment and act of production. MR. GOLDBERGER: Yes. MR. CASSELL: Let's just hang onto that a second. MR. GOLDBERGER: Sure. BY MR. CASSELL: Q. Sir, you've made no effort to collect any of the documents requested here, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth Amendment. BY MR. CASSELL: Q. In the last three weeks, you've made no search at all for the 22 categories of documents requested here, right? MR. PAGLIUCA: Object to form and Re RP eR RR Re OMADNEWNRFOOMRINIADAUNRWNE N pan Page 229 J. Epstein - Confidential documents, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. I want to direct your attention to the item 13, which requests all -- A. Sorry -- MR. GOLDBERGER: Page 9 of the -- of the subpoena. THE WITNESS: Okay. BY MR. CASSELL: Q. -- which request all telephone records associated with you, including cell phone records, from 1999 to present that shown communications with Maxwell, Ghislaine Maxwell. You've taken no steps to secure those documents, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You have, in fact, received electronic and paper records from a cellular telephone provider MAG NA® 58 (Pages 226 to 229) LEGAL SERVICES