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be N Ww ws Oo OY ~] oO WO Ww a OY 20 21 22 23 24 25 Case 1:20-cr-00330-PAE LBUCmax7 Here def Document 743 counsel, ns to the jury civil 1i compensation fund. rebut that because, decade befor With respect tigation in a particular Je SO in Filed 08/10/22 in opening st that a recent motive to Page 242 of 247 tLatements, suggested fabricat rey te in this case was Epstein victim fact, that or more. t to the second prong of statement is proper as a witness when at committ notes th rul tacked on another ground. this statement is of fered expressly to xpressly explained that one of Jane had told someone about this a the rule, th to rehabilitate the declarant's credibility The advisory the grounds for rehabilitation is when that witness's memory has been challenged, Statement much earlier in time closer to the events, SEaAGLEMEenNe rule, as well. would be appropriat under th MS. STERNHE they ar statement that they alleg consistent statement MS. MOE: intending to do. Your Honor, on her. M: My response and here given this witness had made that this second prong of the is still think we need to wait until her cross examination is over. It has to be evaluat THE COURT: Isn't the quest consistent statement with what she MS. STERNHE statement to him is extraordinarily vag testii M: It's not entirely cl [T understand what d whether th she made to Matt is really a prior in our view -- tion whether it's a prior fied on direct? ar because her ue and he did research SOUTH ERN D STR CT RE PORTERS, (212) 805-0300 401 DOJ-OGR-00017604