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Case 1:20-cr-00330-PAE Document 706 Filed 07/12/22 Page6of12 she did not engage in sexualized massages with Jane therefore in no way contradicts Jane’s testimony. Similarly, attempting to identify Michelle Healy as the “Michelle” Jane mentioned lacks a basis in the record. Michelle Healy was far from the only Michelle in the defendant and Epstein’s world. For instance, the list of masseuses in the exhibit marked for identification as Government Exhibit 417 includes three entries for various people named Michelle, none identified with the last name Healy. And although Jane has previously told the Government that Kelly Bovino was involved in group sexualized encounters with her, she did not so testify under oath, and that fact was not put before the jury. Contrary testimony now from Kelly Bovino would only confuse the jury, and not contradict any of Jane’s testimony.” Second, even if the anticipated testimony did impeach Jane’s testimony, it does so only on a collateral matter, namely, Jane’s adult sexual activity. The only time marker the defendant elicited in connection with any of Eva, Michelle, or Kelly is testimony that Jane knew Michelle while Jane was living in New York. (Tr. 533). As Jane testified on direct, she moved to New knowledge of sexualized massages involving Eva Dubin. See 3509-008 at 7 (explaining that Jane was “not sure if [the Eva on the flight records—that is, Eva Dubin] was part of the massages’’); 3509-020 (explaining that Jane “does not remember DUBIN being involved in massages”). ? Even if the defense had elicited the last names of the individuals Jane had in mind, their testimony still would not contradict Jane’s. Defense counsel asked Jane whether she told the Government about Eva, Michelle, and Kelly. Jane was not asked, and did not testify, that these individuals in fact participated in the group sexualized massages. If Dubin, Healy, and Bovino testify that they did not, it in no way contradicts Jane’s testimony about what she did and did not tell the Government in a prior interview. Although defense counsel asked Jane whether Eva and Kelly— but not Michelle—could confirm Jane’s “story,” those questions were continuations of counsel’s questions regarding what Jane had told the Government in earlier interviews. (Tr. 526 (“You said [Eva] joined in with Sophie? . . . . She knew the routine? . . . So she could also confirm your story?”); Tr. 527 (“And you told the government [Kelly] could back up what you were talking about, right?”). 6 DOJ-OGR-00011258