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Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 53 of 69 government has provided "notice" tha ae :: a "victim" in this case, and has disclosed a number of exhibits related to her — school records (GX 781-783); employment records (GX 821-22), photo (GX 332).?’ It is apparent that the government hopes to prove tha i was a "victim" in the sense that she was underage when she had sex with Jeffrey Epstein, without calling her as a witness in this case. Again, if the government offers evidence that the sexual contact observed by between End Mr. Epstein amounts to "sexual abuse" because J was underage, then such testimony would open the door to the mountains of evidence that tends to impeach that assertion. Given the failure to specify the statements that will be elicited, the purposes for which those statements qualify as non-hearsay, depriving the defense of an opportunity to brief whether such statements open the door to credibility challenges of the accuser-declarants}fililmland BE. this Court should deny the motion. *? Tellingly, the government failed to provide an exhibit for JM birth certificate, but did for yyy ME. See GX 11-15. DOJ-OGR-00005508