HOUSE_OVERSIGHT_011448

id.

ne)

life)

H3vlgiu2

145

introduce or (B) adversely inference that are made in 2015 that

had nothing to do with any alleged course of or in furtherance

of a conspiracy. Any alleged conspiracy would have terminated

years ago by operation of many different rules and law. So

Mr. Cassell's entire

conspiracy theory predicate to this has

nothing to do with the four LiButti factors.

And when we there is really zero Honor. First of all these individuals --

relationship is, not

happen in 2000 or 2001.

course of this litigation,

talk about the Lil

Butti factors, you know,

evidence that's been presented to your

, the relationship now, in 2017, between

because that is what the controlling

some relationship

that happened or didn't

It is the relationship during the

not some other litigation. And

indeed, there is no relationship between these folks. At best,

for a brief period, of time,

worked in different capacities for Mr.

that brief period of time is more than

a brief period of time, these folks

Epstein, at best, and

ten years ago.

The other part of this that Mr. Cassell overlooks or

doesn't want to talk about is what really is at issue -- and

this relates to this close present relationship -- does this

witness have some reason to protect Ms.

that's really the inquiry here.

Maxwell. I mean,

Is the witness invoking her,

in this case, privilege against self-incrimination because it's

going to have some benefit to Ms.

Maxwell? Well, there is no

benefit to Ms. Maxwell for the invocation of the Fifth

SOUTHI

ERN DISTRICT R (212) 805-

PORT

ERS, P.C.

0300

HOUSE_OVERSIGHT_011448