UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ILA 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 plaintiffs arguments provides additional compelling reason why Mr. Epstein's Motion to Quash Trial Subpoena should be granted. Before proceeding to elucidate all the many reasons why plaintiff's arguments cannot justify requiring Mr. Epstein to appear personally to repeat the assertions of his Fifth Amendment privilege that he made during his videotaped deposition, it bears noting that the recent March 9, 2017, hearing before the Court provide further illustration of why the Motion to Quash should be allowed. Importantly, the hearing clearly reflects Mr. Cassell's full understanding of the principled basis for Mr. Epstein's assertion of his Fifth Amendment privilege. Tr. 3/9/17 at 39-40. Thus, his arguments that he wishes to call Mr. Epstein as a witness 1 EFTA00589713