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    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 749 Filed 08/10/22 Page 28 of 236 932 LBUCmax1 foundation and have her identify the bag, which is opaque, that contains those items. I think that's all we need to do. At that point, I would just ask for permission to lead to make sure that we're just laying a foundation without describing those items or otherwise displaying them to the jury. THE COURT: And you could say clearly, without describing the items or showing them, just look and did you find these items. MS. MOE: Exactly, your Honor. I'll have a conversation with Special Agent Maguire before she testifies to make sure we're on the same page. MR. EVERDELL: One last issue and then I'll sit down, I promise, your Honor. Special Agent Maguire is also going to testify, as I mentioned, a series of photographs of the exterior and the interior of the residence that were taken during the search. The exterior photographs, I don't think there are that many, I don't think we have an issue with because the exterior of that building did not change from the time period of the conspiracy - which I mentioned several times - ends in 2004 and the time of the search, which is 15 years later in 2019. However, the photographs of the interior - and there are lots of them, photographs of rooms, decorations, artwork, paintings on the walls, photographs on the walls - those are all taken from a time in 2019, which is far removed temporally SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00012542",
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      "content": "foundation and have her identify the bag, which is opaque, that contains those items. I think that's all we need to do. At that point, I would just ask for permission to lead to make sure that we're just laying a foundation without describing those items or otherwise displaying them to the jury. THE COURT: And you could say clearly, without describing the items or showing them, just look and did you find these items. MS. MOE: Exactly, your Honor. I'll have a conversation with Special Agent Maguire before she testifies to make sure we're on the same page. MR. EVERDELL: One last issue and then I'll sit down, I promise, your Honor. Special Agent Maguire is also going to testify, as I mentioned, a series of photographs of the exterior and the interior of the residence that were taken during the search. The exterior photographs, I don't think there are that many, I don't think we have an issue with because the exterior of that building did not change from the time period of the conspiracy - which I mentioned several times - ends in 2004 and the time of the search, which is 15 years later in 2019. However, the photographs of the interior - and there are lots of them, photographs of rooms, decorations, artwork, paintings on the walls, photographs on the walls - those are all taken from a time in 2019, which is far removed temporally",
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    "people": [
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "2004",
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