DOJ-OGR-00018870.pdf

Case 1:20-cr-00330-PAE Document 755 Filed 08/10/22 Page 8 of 262 1713 LC8Cmax1 consider this testimony as any kind of reflection on Mr. Epstein's nor Ms. Maxwell's character or propensity to commit any of the crimes charged in the indictment." So I think that it's obviously a very different instruction with respect to Kate, because this is an alleged victim of the crimes charged in the indictment. This instruction avoids issues that were complicated regarding New Mexico law that I don't think is necessary to get into because it's not illegal sexual activity, as the government has charged in the indictment, which the government has indicated -- you agree with that, right Mr. Rohrbach? MR. ROHRBACH: Yes, your Honor. THE COURT: So that's my view. You can react to it now or think about it. MR. ROHRBACH: I would like to give it some thought, your Honor. We thank the Court for its thoughtfulness. MS. MENNINGER: Same, your Honor. Thank you. THE COURT: Thank you. MS. STERNHEIM: Your Honor, the government, I expect, will be calling, perhaps as its next witness, an individual named Janine Gill. My understanding is she is employed by some property company, either under the auspices or related to the Trump organization. She became an employee in 2007. The government is seeking to introduce two documents, they are Government Exhibit 824 and 823. I believe they will seek to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018870