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 permitted to be heard on his Motion to Quash. 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. Moreover, the hearing held before the Court on March 9, 2017, provides added reason why the Court should grant Mr. Epstein's motion. I. NONE OF THE REASONS ADVANCED BY PLAINTIFF JUSTIFY REQUIRING MR. EPSTEIN TO APPEAR PERSONALLY BEFORE THE JURY. 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. 1 EFTA00589510