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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-AJN 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 witness who can actually say what we believe is that she wasn't living there either until THE COURT: offhand reference and got the years wrong, but to be MR. EVERD BLL: And sometimes details are of we now have a true, which she owned it. And she may have in that deposition gotten the place wrong because she had the prior place in London, time in '92, '93, the place wrong in So what factually misleading impression and Stanhope Mews was the name of she owned that place. the deposition. for the the street. At that So she may have gotten jury based line from offhand deposition transcript quote, on which residenc [ think it sets up is a misleading -- on an a 2019 deposition where it's not exactly clear to in be referring And this Honor. We THE COURT the first place. is an important point feel like -- for the dei she may fense, your : Let me just mak this, all of this SOU is impeachment of sure, becaus THERN D STR CT REPORT BRS, Pes (212) 805-0300 all of a witness who says that DOJ-OGR-00016886