145 H3vlgiu2 1 introduce or (B) adversely inference that are made in 2015 that 2 had nothing to do with any alleged course of or in furtherance 3 of a conspiracy. Any alleged conspiracy would have terminated 4 years ago by operation of many different rules and law. So 5 Mr. Cassell's entire conspiracy theory predicate to this has 6 nothing to do with the four LiButti factors. 7 And when we talk about the LiButti factors, you know, 8 there is really zero evidence that's been presented to your 9 Honor. First of all, the relationship now, in 2017, between 10 these individuals -- because that is what the controlling 1a relationship is, not some relationship that happened or didn't 12 happen in 2000 or 2001. It is the relationship during the 13 course of this litigation, not some other litigation. And 14 indeed, there is no relationship between these folks. At best, 15 for a brief period of time, a brief period of time, these folks 16 worked in different capacities for Mr. Epstein, at best, and de that brief period of time is more than ten years ago. 18 The other part of this that Mr. Cassell overlooks or 19 doesn't want to talk about is what really is at issue -- and 20 this relates to this close present relationship -- does this 21 witness have some reason to protect Ms. Maxwell. I mean, 22 that's really the inquiry here. Is the witness invoking her, 23 in this case, privilege against self-incrimination because it's 24 going to have some benefit to Ms. Maxwell? Well, there is no 29 benefit to Ms. Maxwell for the invocation of the Fifth SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011448