adverse inference motions. We're a mov

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 H3vlgiu2 adverse inference motions. We're a mov reciprocal motions both ways on this. available, if that would be useful. defendant's motion and 689 is our motion. the two motions going, obviously, in di Your Honor is familiar with th 1.35 ing party. There are I have the numbers I believe 673 is the So those would be fferent directions. se issues because of the Epstein adverse inference motion that was argued I think two weeks ago by me, and at that time -- I know you have not yet formally ruled on the motion, but there was extensiv discussion about could we just kick this down the road to the trial and see, you know, what Epstein says at that time and, you know, after he testifies, sort adverse inferenc Again, think I indicated at the time that certainly from Ms. point of view, Mr. Epstein in that way. you haven't ruled on that, out whether there's an but I Giuffre's we would have no objection to handling I want to make clear that we would also have no objection to handling the Marcinkova and Kellen issue in that way as well. You can put them on via deposition, and then we could sort out in the context of the case with a full record whether an adverse inferenc But we surface you'd have to do on the fly in the allegations, of course, that have b the middle of trial. is appropriate. the issue for you now so it wouldn't be something And all I think it's important to put Kellen and scheme, if you will. The top of the conspiracy is Mr. n made here, Marcinkova on the conspiracy Epstein, SOUTHERN DISTRICT REPORT ERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011438