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be N Ww ws Oo OY ~] oO WO a oO = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 157 of 197 2698 LCHCmax5 THE COURT: And that's in the record; right? MR. EVERDELL: We're going to have to add that as part of the stipulation. We have the land registry records for that residence now, as well, showing her ownership of that residence, but we still want to be able to counter what I think is an incorrect inference to the jury that she wasn't there. Yes, I understand there is a deposition where she made an offhand reference and got the years wrong, but we now have a witness who can actually say what we believe to be true, which is that she wasn't living there either until THE COURT: MR. EVERDELL: And sometimes details are of she owned it. And she may have in that deposition gotten the place wrong because she had the prior place in London, and Stanhope Mews was the name of the street. At that time in '92, '93, she owned that place. So she may have gotten the place wrong in the deposition. So what I think it sets up is a misleading -- factually misleading impression for the jury based on an offhand deposition transcript guote, one line from a 2019 deposition where it's not exactly clear which residence she may be referring to in the first place. And this is an important point for the defense, your Honor. We feel like -- THE COURT: Let me just make sure, because all of this, all of this is impeachment of a witness who says that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014263