Case 1:20-cr-00330-PAE Document 761 _ Filed 08/10/22 Page 207 of 246 2502 LCGCmax6 Aznaran -— direct 1 travel records show her whereabouts and show her traveling 2 around the same time when she's still in contact with Jeffrey 3 Epstein. 4 THE COURT: What's the relevance of that? 2) MR. EVERDELL: Your Honor, I don't plan to make much 6 of an argument about those records that are happening after the 7 charged time period -- 8 THE COURT: You haven't asserted any relevance with 9 respect to after the -- where is the government with respect to 10 the time cutoff request? 11 MS. POMERANTZ: Your Honor, our proposal would be that 12 it would be redacting anything that postdates the charged 13 conspiracy. 14 MR. EVERDELL: Your Honor, there is probably a 15 practical solution that we could come to with this, because I 16 don't think that we -- you want to give me a moment, your 17 Honor. I'll just confer with my colleagues. 18 THE COURT: Okay. 19 MR. EVERDELL: Your Honor, one other point about Kate 20 in particular, I believe her testimony was that she was on 21 public assistance at some point in her life that correspond to 22 when she's flying all over the world. So I think that those 23 records —-— 24 THE COURT: Is that during the time of the charged 25 conspiracy? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00016690