DOJ-OGR-00008380.pdf

--- Page 1 --- The extracted text is: **Header:** Case 1:20-cr-00330-PAE Document 545 Filed 12/15/21 Page 7 of 9 **Text:** 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 **Footer:** DOJ-OGR-00008380