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Case 1:20-cr-00330-PAE Document545 _ Filed 12/15/21 Page4of9 1681-83). e Scarola was present for Carolyn’s the meetings the Government listed by the defense. (Tr. 1684; Def. Letter at 3-4). e Carolyn received $2,804,000 from the Epstein Victims Compensation Program, not counting the $446,000 she had previously received from her claims against Epstein and Sarah Kellen (Tr. 1688-89). Accordingly, the defendant has already obtained through Carolyn much of the testimony it anticipates from Scarola. There is no need for Scarola to testify to information already obtained from Carolyn, and it obviously does not impeach Carolyn for Scarola to confirm her answers. Nearly all of additional testimony the defendant proposes to elicit from Scarola is irrelevant and non-impeaching. It does not matter that Scarola is a member of the Florida bar (Def. Letter at 2), nor are the additional specifics of the Government’s unsuccessful efforts to contact Carolyn probative (id. at 3).' It says nothing about Carolyn that Scarola copied counsel for other victims on an email. (id. at 2). None of that information impeaches Carolyn’s testimony in any way— rather, it is entirely consistent with her testimony.” The defendant argues this testimony is relevant to “establish the timeline of Carolyn’s cooperation with the government and her motive and bias in testifying against Ms. Maxwell, in particular the fact that Carolyn was unresponsive and uncooperative until there was the prospect ' The Government would stipulate to the specific dates of meetings between Scarola, Carolyn, and the Government. (See Def. Letter at 3-4). 2 The defendant would also elicit from Scarola that, during a 2020 meeting, Scarola told the Government that he had shown Carolyn a picture of the Epstein associate with the same name as Jane, but Carolyn could not identify the person at the time. But the defendant did not ask Carolyn about that person, so this testimony would not impeach Carolyn—to the extent it is not privileged. 4 DOJ-OGR-00008377