1.35 H3vlgiu2 ih adverse inference motions. We're a moving party. There are 2 reciprocal motions both ways on this. I have the numbers 3 available, if that would be useful. I believe 673 is the 4 defendant's motion and 689 is our motion. So those would be 5 the two motions going, obviously, in different directions. 6 Your Honor is familiar with these issues because of 7 the Epstein adverse inference motion that was argued I think 8 two weeks ago by me, and at that time -- I know you have not 9 yet formally ruled on the motion, but there was extensive 10 discussion about could we just kick this down the road to the 1a trial and see, you know, what Epstein says at that time and, 12 you know, after he testifies, sort out whether there's an 13 adverse inference. Again, you haven't ruled on that, but I 14 think I indicated at the time that certainly from Ms. Giuffre's 15 point of view, we would have no objection to handling 16 Mr. Epstein in that way. I want to make clear that we would de also have no objection to handling the Marcinkova and Kellen 18 issue in that way as well. You can put them on via deposition, 19 and then we could sort out in the context of the case with a 20 full record whether an adverse inference is appropriate. But 21 we surface the issue for you now so it wouldn't be something 22 you'd have to do on the fly in the middle of trial. And all 23 the allegations, of course, that have been made here, I think 24 it's important to put Kellen and Marcinkova on the conspiracy 25 scheme, if you will. The top of the conspiracy is Mr. Epstein, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011438