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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-PAE Document 465 Filed 11/15/21 Page 62 of 127 62 LB15MAX2 TH | COURT: Ms. Menninger? MS. MENNINGER: Your Honor, I ama little confused but what I think I understand the government is saying is that knowledge after the conspiracy is relevant to the time frame of the conspiracy. I don't believe that the witness we are talking about, who didn't start working until after the time of the conspiracy for Mr. Epstein, would be able to set forth the foundation that they're claiming. I believe that this is more likely to be a trial-time testimony decision because I think there will be some pretty substantial objections to the ability of this witness to authenticate the document which I know your Honor is aware from other briefing, is what we consider to be from a very suspect source and obtained years later. There is a lot of notations and things on it that will not be anything that this witness can attest to. T think it is Exhibit 52. THE COURT: Yes. MS. MENNINGER: don't think it is relevant to the time period of the conspiracy. THE COURT: Right. I guess the question, given the pieces of authentication that the government intends to offer through different witnesses and what sounds like lines of cross-examination as to those pieces, I think at that point am potentially -- at least the government will have to proffer, put forward questions and get answers from the witness that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007113