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Case 1:20-cr-00330-PAE Document 731-1 Filed 07/14/22 BANISH The Honorable Alison J. Nathan BOYLE December 6, 2021 LLP Page 4 During her cross-examination of Jane, Ms. Menninger did not ask Jane if she was told that cooperating with the government would “help her case.” Rather, the testimony on this issue is as follows: Q. At any point during your cooperation with the government, including testifying, you knew that your cooperation with the government, including testifying, would benefit you in your civil litigation against the Epstein estate and Ms. Maxwell; correct? A. No, I don't know that. Q. You knew that cooperation with the government, including testifying, would benefit you in your claim for the victims' compensation fund; correct? A. No, I don't know that. (U.S. v. Maxwell Trial Testimony, 12/1/21 at 581:2-11). Even if Mr. Glassman said to Jane at some time during her civil case before she decided to settle it (i.e. January-December 2020) that he thought cooperating with the government would “help” that civil case, that doesn't mean that Jane "knew" that to be a fact. The veracity and/or significance of a statement Ms. Moe believes Mr. Glassman made to her about an alleged statement he made to his client is simply irrelevant. Jane respectfully requests that Ms. Maxwell’s motion be denied outright. But if the Court is inclined to entertain the motion further, Jane requests that Ms. Maxwell provide the precise question or questions that Ms. Maxwell’s counsel intends to ask Mr. Glassman. And that Mr. Glassman be permitted time to obtain an advisory opinion from ethics counsel and perhaps from the California State Bar as to whether he would be permitted to answer such a question or questions. DOJ-OGR-00011410