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Case 1:20-cr-00330-PAE Document545 Filed 12/15/21 Page/7of9
testimony. Edwards’s anticipated testimony about the U-Visa is therefore inadmissible, and in any
event, should be precluded under Rule 403 for the same reasons as testimony from Scarola.
C. Robert Glassman
In addition to the Glassman’s statement which is already the subject of litigation, the
defendant identifies two additional statements which she seeks to offer: (1) Glassman’s exchange
with the Government about Jane’s recollection of seeing The Lion King on Broadway, and (2)
Glassman’s communications with the EVCP in which Glassman sought a larger award from the
Program.
Jane’s statements in The Lion King e-mail do not impeach Jane’s testimony. Jane
acknowledged that she originally told the Government that she flew to New York first with Epstein
and the defendant to see The Lion King when she was 14, but she later realized she was incorrect
in her timeline, and she saw the show on a different trip. (Tr. 503). The defense cross-examined
her on this point at length (Tr. 503-12). After her recollection was refreshed with the specific
email attached as Exhibit 1 to the defendant’s letter, Jane also acknowledged that her “lawyer
communicated to the government [Jane’s] recollection that, in fact, [she] had seen The Lion King
Broadway show and not the movie.” (Tr. 509-10). She confirmed details, including that she sat
in mezzanine seats and that Epstein “bragged about getting those seats because he knew the
director,” and that all of that information was conveyed to the Government in response to questions
about her timeline from the Government. (Tr. 510-11).
Jane confirmed every question the defense asked about the content of this email, except
questions which drew sustained objections because they asked Jane about the substance of her
conversations with Glassman. (Tr. 510-12). Calling Glassman to testify to the same information
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| Filename | DOJ-OGR-00008380.jpg |
| File Size | 675.5 KB |
| OCR Confidence | 94.7% |
| Has Readable Text | Yes |
| Text Length | 1,939 characters |
| Indexed | 2026-02-03 17:34:21.086263 |