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Re Re eR RR RH OMADNARWNKFOTOOMINIAUNUARWNH N pan Case 1:15-cv-07433-LAP Document 1335-6 Filed 01/09/24 Page 95 of 134 Page 370 J. Epstein - Confidential BY MR. CASSELL: Q. What is your arrangement with Ms. Maxwell with regard to paying any settle -- any judgment that might be reached against her in this case? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Ms. Maxwell has had discussions with you about whether you would pay a judgment in this action against her, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Your interests in Ms. Maxwell are compatible in this case, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Both you and Ms. Maxwell are hoping that the case would be dismissed, true? MR. PAGLIUCA: Object to form and OMANDNRWNK Page 372 J. Epstein - Confidential Alan Dershowitz with regard to this litigation, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. MR. GOLDBERGER: And attorney-client privilege. BY MR. CASSELL: Q. You are in a joint defense arrangement with Alan Dershowitz at this time? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. MR. GOLDBERGER: Attorney-client privilege -- I'm sorry. Attorney-client privilege, and to the extent there is a confidentiality agreement in place or -- or a joint defense agreement, I would object on that basis. BY MR. CASSELL: Q. You have a common interest agreement with Alan Dershowitz, right? MR. PAGLIUCA: Object to form and foundation. Page 371 J. Epstein - Confidential foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Previously you sent e-mails to Ms. Maxwell indicating your desire to have the publicity in this case die down, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Ifthe case were to settle, that would help the publicity in this case die down, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. If this case were to resolve, that would be useful for your purposes and Maxwell's purposes, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You have also been coordinating with Page 373 J. Epstein - Confidential THE WITNESS: Fifth. MR. GOLDBERGER: Attorney-client privilege. BY MR. CASSELL: Q. You have a common interest with Alan Dershowitz in this litigation, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You have a common interest with Ghislaine Maxwell in this litigation, right? MR. PAGLIUCA: Asked and answered, this question. I'm going to object to form and foundation. THE WITNESS: Fifth. MR. CASSELL: I have no further questions. MR. PAGLIUCA: I have no additional questions. MR. GOLDBERGER: Excellent. MR. CASSELL: Thank you. VIDEO TECHNICIAN: The time is 2:08. This concludes the deposition. MAG NA® 94 (Pages 370 to 373) LEGAL SERVICES