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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 LC1LVMAX7 TH | (At TH | MS. her mother were Document 745 ‘Filed 08/10/22 Page 237 of 264 648 Matt - direct COURT: Okay. sidebar) COURT: What do you expect the witness to say? MOE: That he recalls being present when Jane and in a room. He recalls Jane saying to her mother, How could you not know the money wasn't for free? How could you not know? THE COURT: Is that in 3500 material? MS. MOE: Yes, I'm happy to pull it up. MS. STERNHEIM: There's been no testimony by Jane about confrontation with her mother at this time. She testified that her mother was irate regarding a guidance counsellor, Jeffrey Epstein. THE COURT: So but she didn't go toe-to-toe with her mother about it's in the 3500 material; it's not the first time you're hearing it. MS. STERNHEIM: don't recall if it's this witness or her brother. THE COURT: Okay. MS. STERNHEIM: But even if it is in the 3500 material, if it is not on the direct of Jane, why can it be @) ffered ata (2) MS. 11? fered as a prior consistent statement when it never was MOE: This is a statement from Jane to her mother essentially acknowledging she was abused, expressing SOUTH ERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00017846