Case 1:15-cv-07433-LAP Document 712 Filed 03/14/17 Page 1 of 11 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S RESPONSE TO JEFFREY EPSTEIN'S MOTION TO OUASH TRIAL SUBPOENA Plaintiff, , by and through her undersigned counsel, hereby files this response to Jeffrey Epstein's Motion to Quash Trial Subpoena. No good reason having been provided why this important witness should not have to appear at trial, the motion to quash should be denied. BACKGROUND As the Court is aware from previous briefing, Jeffrey Epstein is an important witness in this case. See, e.g., Plaintiff's Statement of Undisputed Facts in Response to Defendant's Motion for Summary Judgment at 4-27 (recounting details of Epstein's and Defendant's sex trafficking and sex abuse conspiracy); see also Plaintiff Reply in Support of Motion to Present Testimony from Jeffrey Epstein for Purposes of Obtaining and Adverse Inference (explaining numerous questions that intends to ask Epstein as trial). Accordingly, has served him with a trial subpoena, through Epstein's legal counsel. Epstein's, through counsel, now has filed a motion to quash to subpoena. DISCUSSION 1 EFTA02802754