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Case 1:20-cr-00330-PAE Document 708 Filed 07/12/22 Page4of15 negotiate an appropriate stipulation with the defense. As to these statements, the Government would stipulate that a meeting occurred at which the relevant law enforcement officer took notes of the meeting; that the notes are not verbatim, but the officer believes them to be accurate; and that the notes contain the specific inconsistent statement.” Other prior inconsistent statements offered by the defense, however, are inadmissible, either because they are not inconsistent with the witness’s testimony, concern a collateral matter, or were already read into the record (such that additional extrinsic evidence on the point would be cumulative and cause undue delay). For convenience, the Government provides the following tables: A. Jane Trial 3500 Material Quote Government Testimony Position 375:20 — 376:20 | 3509-008, p. From when Jane met Epstein to | No objection 12, 4th when she moved to New York paragraph, last | she lived in the same house in sentence Florida. This house was in a gated community called Bear Lakes. It was a 3 bedroom house. 447:2 — 447:20 | 3509-002, p.1 | GM walked by w/ dog. JE came Objection. The up to meet her. shorthand notes in 3509-002 was turned into an FBI 302 which makes clear that the statement was consistent. See 3509-001 p.1, second paragraph. > The defense letter refers to particular paragraphs in the 3500 material. While that is helpful for purposes of the inquiry now before the Court, the Government would not stipulate to the entire paragraphs, which contain material that is often neither consistent nor inconsistent. 4 DOJ-OGR-00011271