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Case 1:20-cr-00330-PAE Document 761 Filed 08/10/22 Page 14 of 246 2309 LCGVMAX1 1 THE COURT: [ was sort of leaning that way when 2 thought the attorney was going to come testify who could be 3 crossed on this precise question. But you want it to just come 4 in -- you want a fact not in issue, which is the ownership 5) question, you want an inference from ownership -- ownership is 6 confusing; but the inference from the timing of ownership as to 7 when she lived there, which is contradicted by deposition 8 testimony that would come in from Ms. Maxwell. 9 MR. EVERDELL: Your Honor, I think we have records 10 which we'd have to find and anticipate this being the issue. 1] But Ms. Maxwell had another place in London at a street called 12 Stanhope Mews, think it was 69 Stanhope Mews. And we may be 13 able to find the title records that she sold it, because she 14 had that prior to the Kinnerton Street residenc And I think 15 if you have -- we'd have to look for those. I think we 16 probably can find them. But they would show that she had 17 another place until she bought this new place. 18 So I think that is a fair inference to say that if 19 somebody owned another place and didn't buy another place until 20 later, that they are not living at that new place if they owned 21 the other place. That's just common sense. 22 THE COURT: And why can't the attorney who you had 23 proffered as the witness for this testify? 24 MR. EVERDELL: Your Honor, if we need the attorney, we 25 can try to get him here, but we just couldn't get him here SO UTHERN D STR CT R G iPORT ERS, (212) 805-0300 DOJ-OGR-00013873