HOUSE_OVERSIGHT_011446

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they're going to say if we don't have an opportunity to present them to the jury. The Court will recall the extraordinary lengths to

which Ms. Giuffre had to go to procure their testimony. They

finally were able to secure it, and they should be presented.

Also -- I think you'll be hearing these issues next week we used some leading questions during the deposition. We tried to also use some nonleading. Leading questions can be

used when? When you have a witness who's associated with the

party on the other side. Well, we said they're ina

conspiracy. I can't imagine a case where there would be a

clearer example of when leading questions would be appropriate.

The final argument they made, I think last night in

their late replies was that we somehow missed the deadline in

taking their deposition. What they don't disclose I think in

their papers is, your Honor will recall that we had to come to you, obtain an application for alternative service, and then, as a result of that, they came in. We did all these things

with the Court's blessing and approval of taking depositions.

Those schedules were discussed with opposing counsel. And as soon as we'd taken the deposition, within approximately a week, we provided the designations. That was back in February of this year. There's no prejudice.

So for all these reasons, we would ask that we be

allowed to present two of the co-conspirators in the witness

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

HOUSE_OVERSIGHT_011446