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OMINDNKRWNK Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 87 of 134 Page 338 J. Epstein - Confidential touch with each other because of interactions that you've had of a business nature, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please describe the ways in which you and Maxwell's affairs are intertwined currently. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please describe the way yours and Maxwell's business affairs are intertwined currently. MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You were asked -- and this is kind of a setup question again. You were asked some questions about a lawsuit filed by Jane Doe 1 and Jane Doe 2 against the United States seeking to enforce rights under the Crime Victim Rights Act. Do you recall those general OMNDWNWKRWNE Page 340 J. Epstein - Confidential non-prosecution agreement until it was concluded, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. The non-prosecution agreement binds the U.S. Attorney's Office for the Southern District of Florida, correct? MR. PAGLIUCA: Object to form and foundation. BY MR. CASSELL: Q. I'msorry. Let me rephrase that. The non-prosecution agreement binds only the U.S. Attorney's Office for the Southern District of Florida, correct? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. MR. GOLDBERGER: And attorney-client privilege. BY MR. CASSELL: Q. Your non-prosecution agreement does not cover sex offenses in -- you have committed in the Page 339 J. Epstein - Confidential questions? A. Yes. Q. I want you to assume for a moment that that lawsuit is dismissed tomorrow. If the lawsuit were to be dismissed tomorrow and I were to ask you all of the same questions the day after tomorrow, you would give the same answers, wouldn't you? MR. PAGLIUCA: Object to form and foundation. MR. GOLDBERGER: Why don't you do that and we'll find out. THE WITNESS: Fifth. BY MR. CASSELL: Q. That case isn't going to be thrown out, though, because it's meritorious, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. MR. GOLDBERGER: And attorney-client privilege. BY MR. CASSELL: Q. In fact, you conspired with the U.S. Attorney's Office to conceal the existence of your Page 341 J. Epstein - Confidential State of New York, does it? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. MR. GOLDBERGER: Attorney-client. BY MR. CASSELL: Q. The non-prosecution agreement does not cover sex crimes committed in, for example, the U.S. Virgin Islands or New Mexico, does it? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. MR. GOLDBERGER: Attorney-client. BY MR. CASSELL: Q. You would still be unavailable to testify in the sense that you would have invoked your Fifth Amendment even without that lawsuit, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. MR. GOLDBERGER: Attorney-client. BY MR. CASSELL: Q. Which prosecution -- I'm sorry. Which jurisdictions are you fearful might MAGNA® 86 (Pages 338 to 341) LEGAL SERVICES