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be NO Ww ws Oo OY ~] oO Ke) a oO he be No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 Case 1:20-cr-00330-PAE Document 761 'd appreciate that so that Filed 08/10/22 —- direct Page 146 of 246 2441 can have LCGCmax4 Loftus MS. STERNHEIM: all of the documents in front of THE COURT: Okay. MS. STERNHEIM: THE COURT: Just so basic idea or two conversations that he had with calling Kate, is that you want this witness me. Thank you very much. can marinate on it. So the to testify about one this witness, who we're the one or two conversations that he had with Kate in which -- and his proffered testimony is that, at one point, Kate said, regarding the subject of Jeffrey Epstein, that it, quote, fell right into my lap. MS. STERNHEIM: That's correct. THE COURT: Let's start with that one. What is the purpose for which it is being offered? MS. STERNHEIM: It certainly shows motive and bias on the part o f Kate. much as they is anything but placing her in the category of the statement of There is a someone who monetary issue here. That is not feels that they are a victim as feel -- it suggests that it's an opportunity that victim. It sounds more like someone who is interested in a windfall. THE COURT: So broadly stated, the purpose for which it's being offered? MS. STERNHEIM: s her bias and motive. THE COURT: And the government's objection? MR. ROHRBACH: The government's objection is that this SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00016629