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Case 1:20-cr-00330-PAE Document 761 _ Filed 08/10/22 Page 23 of 246 2318 LCGVMAX1 1 MS. STERNHEIM: Thank you. 2 THE COURT: Okay. What other open issues do we have 3 that we can deal with now, counsel? 4 MR. EVERDELL: Your Honor, I think there are som 5) issues with this first witness that I just want to raise with 6 the Court first. 7 THE COURT: That I have briefing on? 8 MR. EVERDELL: These are things that we've tried to 9 talk with the government about. I don't think it's going to be 10 a major dispute. 11 THE COURT: Okay. I just wanted to make sure I hadn't 12 missed it. 13 MR. EVERDELL: You did not miss anything. 14 THE COURT: Okay. Go ahead. 15 MR. EVERDELL: The first witness is Ms. Espinosa. 16 THE COURT: Right. 17 MR. EVERDELL: So the first issue, which I think the 18 government and the defense agr on, is that there's a line of 19 cross that we ask the government if they plan to get into, and 20 they have agreed that they won't. And that's related to the 2] following, which is that Ms. Galindo was a defendant in a civil 22 lawsuit by one of the Epstein -- not one of the accusers in 23 this case, but a different person. And so I've asked th 24 government that they not get into that; they've agreed that 25 they won't cross Ms. Espinosa about that. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00013882