DOJ-OGR-00014361.jpg
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Case 1:20-cr-00330-PAE
LCT1MAX1
one moment.
Document 765
Filed 08/10/22
Page 57 of 95 2795
Oh, and we'll again change, on line 23, page 49, the
word "reads" to "alleges."
MR. EVERDELL: Yes, your Honor.
THE COURT: Okay. Next.
MR. EVERDELL: Same page, page 50, your Honor,
line 18, just going back, these are overt acts with respect to
Count Five.
THE COURT: Mm-—-hmm.
MR. EVERDELL: The third one, which begins on line 17,
between -- oh, yes. "Between in or about 2001 and in or about
2004, Epstein's employees, including at times Maxwell, sent
Carolyn gifts, including lingerie, etc." I don't think there's
any evidence in the record that Maxwell sent
fact,
sending anything.
record that Maxwell was sending the gifts,
I think the Fed
should be excluded.
MR. ROHR
the record.
BACH:
the grand jury charged, but that
That's
Ex records show that it
fine,
So
is
fine,
your Honor.
given the state of
y gifts. In
sn't Maxwell
I don't think there's any testimony in the
[ think that
This is what
THE COURT: Okay.
MR. ROHRBACH: But to be clear, the government is fine
with including the clause -- cutting the clause "including at
times Maxwell."
SOUTHERN DISTRICT REPORTERS, P.
(212)
805-0300
DOJ-OGR-00014361