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Case 1:20-cr-00330-PAE Document 456 Filed 11/12/21 Page9of10 Page 9 attached to them, suggesting that electronic equipment had been removed in advance of the search. The absence of that electronic equipment, which resulted from Employee-1 removing the equipment at Epstein’s instruction, will both corroborate that witness’s testimony and will help the jury understand why they have not been presented with any electronic evidence from the 2005 search. Finally, while the Government does not seek to offer this statement for its truth, the Government notes that it included the statement within the Rule 801(d)(2)(E) disclosure letter because that is an alternative basis of admission. Like the first exemplar, this statement was made during the sex trafficking conspiracy that continued past 2004. The statement was also in furtherance of the conspiracy because it related to efforts to protect co-conspirators from legal jeopardy so that the conspiracy might continue. Cf United States v. Johnson, 469 F. Supp. 3d 193, 213 (S.D.N.Y. 2019) (“[A] ‘plot to silence [a] witness[ ]’ is admissible as aco- conspirator statement, because the plot “furthers the goals of the conspiracy in that the 3999 [conspiracy's objectives] would be facilitated by the acquittal of all the defendants’” (quoting United States v. Arrington, 867 F.2d 122, 130 (2d Cir. 1989)). Accordingly, although the Government does not anticipate offering this statement for its truth under Rule 801(d)(2)(E), it would also be admissible on that basis. DOJ-OGR- 00006961