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Case 1:20-cr-00330-PAE Document 708 _ Filed 07/12/22 Page 12 of 15 of ’02 and the last time you went was August of ’03. A. Yeah by extrinsic evidence C. Annie Trial Testimony 3500 Material Quote Government Position 2151:2 — 16 3514-001, p. 2, 2d full paragraph Originally Maria was going to accompany Annie to New Mexico. Objection. Although the witness testified that she did not recall making the statement, she acknowledged that the statement is contained in the 302. There is no basis for further impeachment. 2160:12 — 2161:25 3514-001, p. 3, 2d full paragraph The chef prepared dinner and all three ate together. Objection. Not inconsistent with the witness’s testimony. Also, whether a chef prepared dinner is a collateral matter. 2165:7 — 2166:6 3514-001, p. 2, last paragraph They spent a significant amount of time horseback riding. Objection. Not inconsistent with the witness’s testimony. The witness did not deny making the statement on page 2166. Also, whether the witness went horseback riding for a significant amount of time is collateral. 2169:22 — 2170:12 Omission Never told the government in any interview “explain[ing| why [the boots] were not used previously and then I did wear them.” Objection. This is an elaboration, not an inconsistency by omission, with earlier {2 DOJ-OGR-00011279