Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff Case No. 15-cv-07433-RWS v. HEARING REQUESTED Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO PLAINTIFF'S RESPONSE TO HIS MOTION TO QUASH TRIAL SUBPOENA Mr. Epstein respectfully requests that he be per

to repeat his assertion of his Fifth Amendment privilege. Second, plaintiff argues that Mr. Epstein should be required to appear because defendant Maxwell has objected to the use of Mr. Epstein's deposition testimony, claiming that he is not an unavailable witness. Response at 3. This is simply a non-i

Case No. 15-cv-07433-RWS v. HEARING REQUESTED Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO P

intiff's case in chief. Nor does speculation that Ms. Maxwell might object to the authenticity of the "blackbo

n.4. 4 EFTA00589513 needed to prosecute [him] for a federal crime." Rajah v. Mukasey, 544 F.3d 427, 441 (2d Cir. 2008), quoting United States v. Hubbell, 530 U.S. 27, 38 (2000). See, e.g., United States v. Greenfield, 831 F.3d 106, 114 (2d Cir. 2016)("the Fifth Amendment privilege has been found to

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff Case No v. Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO PLAINTIFF'S RESPONSE TO HIS MOTION TO QUASH TRIAL SUBPOENA Far from being an "important witness," as plaint

to repeat his assertion of his Fifth Amendment privilege. Second, plaintiff argues that Mr. Epstein should be required to appear because defendant Maxwell has objected to the use of Mr. Epstein's deposition testimony, claiming that he is not an unavailable witness. Response at 3. This is simply a non-i

ERN DISTRICT OF NEW YORK Plaintiff Case No v. Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO P

intiff's case in chief. Nor does speculation that Ms. Maxwell might object to the authenticity of the "blackbo

the chain of evidence needed to prosecute [him] for a federal crime." Rajah v. Mukasey, 544 F.3d 427, 441 (2d Cir. 2008), quoting United States v. Hubbell, 530 U.S. 27, 38 (2000). See, e.g., United States v. Although plaintiff has argued elsewhere that the existence of such photographs is a foregone c

orking sites, and e-mails. Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 18. Any and all docume

unications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, t

ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,

tance where "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence, Case 9:08-cv-80119-K

orking sites, and e-mails. Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 18. Any and all docume

unications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, t

ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,

tance where "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence EFTA00222080 Case 9:0

No. 2 v. Epstein Page 17 Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting

munications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes,

ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,

nces as here "the act of producing documents in response to a subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence, Title 6, Chap. 13. The

ils (for SI parties) Indkidual's Name Glikisine Maxwell Date et Birth: Country of Residence: Country e

w Jones, DM) 12 yes ONG negative results found E)Yes Otto Denial Orders checks corrpkte IR1 Ye. ONo negative results found • yes @No Marondae.Hubbell searched (Levyerkkaw Fenn only) O Yes ONO negative results found • Yes O No D. Please sonnetize any negative resuks from the database searches I