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Case 1:20-cr-00330-PAE Document507 _ Filed 11/24/21 Page 20 of 28 It remains theoretically possible that Dr. Hall’s interview with Minor Victim-4 will become relevant for impeaching her with a prior inconsistent statement. At present, however, the Government does not expect that Minor Victim-4’s testimony will be contradicted by statements she made to Dr. Hall. And to be clear, Minor Victim-4’s expected testimony about the defendant’s involvement in Epstein’s scheme is not inconsistent with the fact that Minor Victim-4 did not describe those instances to Dr. Hall. “It is well settled that for two statements to be inconsistent, they need not be diametrically opposed. Nevertheless, the statements must be inconsistent.” United States v. Trzaska, 111 F.3d 1019, 1024-25 (2d Cir. 1997) (citations and internal quotation marks omitted). In 7rzaska, the Circuit explained that a witness’s statement on one occasion that his son was willing to give away certain guns was not inconsistent with the witness’s statement on another occasion that his son was obsessed with different guns, or guns in general. /d. Similarly, that Minor Victim-4 described to Dr. Hall certain aspects of Epstein’s abuse that did not involve the defendant is not inconsistent with describing other aspects that did involve the defendant. In addition, the defendant does not need Dr. Hall’s testimony to inform the jury that Minor Victim-4 has not always disclosed the defendant’s role in Epstein’s abuse. Minor Victim-4 also failed to mention the full extent of the defendant’s role during her first FBI interview. Because the Government believes that in this interview—unlike the Hall interview—Minor Victim-4 was asked questions that would have referenced the defendant in a complete answer, the Government 18 DOJ-OGR-00008061