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 plaintiff asserts, Jeffrey Epstein would not be a witness at all in any real sense even if forced to personally appear before the jury. Plaintiff has not provided the Court with any reason which withstands scrutiny as to why it would further the interests of justice for Mr. Epstein to be compelled to appear personally to assert his Fifth Amendment privilege. Indeed, the weakness of plaintiff's arguments provides additional compelling reason why Mr. Epstein's Motion to Quash Trial Subpoena should be granted. Mr. Epstein respectfully requests that he be permitted to be heard on his Motion to Quash. Plaintiff first contends that Mr. Epstein should be required to appear because live testimony is preferable to deposition testimony. That may be true when the witness actually has testimony to give regarding the matter on trial, but that is not the case here. In neither United States v. International Bus. Machines Corp., 90 F.R.D. 377 (S.D.N.Y. 1981), or Napier v. Bassard, 102 F.2d 467 (2d Cir. 1939), on which the plaintiff relies, Response at 2, did the witnesses at issue assert their Fifth Amendment privileges; instead, they had actual substantive EFTA00585747