12 H3VOGIU1 ih any questions we wanted to ask him about Epstein or Maxwell he 2 says he's got an attorney/client privilege. So we're hand-tied 3 because we can't ask about the issues that we need to ask about 4 with respect to that witness. So in my view, it's highly 5 prejudicial to have him as a witness at trial when, again, our 6 claims are not against him, and we have those issues. 7 Now, you did have -- in your February 2nd order, you 8 also precluded us from asking questions that we contended were 9 non-Fifth Amendment questions of Jeffrey Epstein about 10 Dershowitz, holding that those were not relevant. So we're in Pi. a situation where we have another witness that we are not able 12 to elicit all of the information we need to be able to prove 13 the truth or falsity of that, and again, it would be subject to 14 a number of mini trials on that issue of Mr. Dershowitz. 15 So with respect to those three categories -- and it 16 also allows them to use the attorney/client privilege as a de sword and a shield in the midst of a trial, which is inherently 18 unfair to my client, as well. 19 So in our view, it's highly prejudicial under 403. 20 Those groupings should not come in. It should not be about, 21 for example, Clinton and whether or not he was on an island, or 22 Mr. Dershowitz or these other world leaders, it should be about 23 the defendant and her statements that my client was lying when 24 she claimed to be abused and trafficked in those statements. 29 THE COURT: Just a second. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011315