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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-AJN Document 763 Filed 08/10/22 Page 156 of 197 2697 LCHCmax5 correct? MR. EVERDELL: That's right, your Honor. THE COURT: You didn't see a need to find other witnesses regarding -- MR. EVERDELL: And the reason why we had to is because that is what we were planning to do all along, to show when she was at that place. However, when we litigated this issue and discussed it yesterday, the Court the government raised the deposition transcript from the defendant who said, in sort of an offhand way, if you read the transcript, '92, '93 was when I was there. Then it became an issue of when she was actually residing there as opposed to when she owned it. We thought if the stipulation was going to have to involve that testimony, as well, we then now needed a witness, because the facts we believe to be true was that she was not only -- did not own it until then, she was not there, she did not reside there, she wasn't renting it. There was another couple that was in that house living there until she owned it, purchased it, and then owned it, and then moved in. THE COURT: So really, this is a new let me s if I get this right. MR. EVERDELL: Your Honor, if I can add one more thing. She had another residence in London prior to the Kinnerton Street residenc SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00016885