DOJ-OGR-00013211.pdf

--- Page 1 --- **Document Header** Case 1:20-cr-00330-PAE Document 753 Filed 08/10/22 Page 198 of 264 **Page Content** LC7Cmax6 Carolyn - cross things that are in the complaint. THE COURT: So that's a long way of getting to my -- responding to my first question. MR. PAGLIUCA: Yes. THE COURT: What paragraph is inconsistent? MR. PAGLIUCA: Well, the fact that Ms. Maxwell -- THE COURT: Point me to a paragraph. MR. PAGLIUCA: All of the paragraphs, your Honor. THE COURT: On the same theory you just pronounced? MR. PAGLIUCA: Yes. THE COURT: So then on your second theory, can you point to any inconsistency? MR. PAGLIUCA: Well, these are all omissions, your Honor, factual. So paragraph 8, for example, the witness has testified now that she was the subject of penetration and intercourse by Epstein. Paragraph 8 does not include that. Paragraph 9, I think, is an expansion. We have only Kellen, often calling -- excuse me. 11A is what I'm looking at. THE COURT: So other than the omission theory, is there an inconsistency you're pointing to? MR. PAGLIUCA: No. THE COURT: Is there any other? I understand your omission theory, I'll hear from Ms. Comey on that in a second, I do have a question for you on it, and I need to read the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 **Footer** DOJ-OGR-00013211