{
  "document_metadata": {
    "page_number": "11",
    "document_number": "745",
    "date": "08/10/22",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 11 of 264 417 LC1VMAX1 The government also doesn't agree with the defense's broad statement that anything that goes to this witness's memory is a noncollateral matter. It's hard for us to know now exactly what they plan to do. The government thinks we should take that as it comes. But I think there's sort of broad agreement about the general principles here, your Honor. MR. EVERDELL: If there's broad agreement, your Honor, then there shouldn't be objections. If we have an issue with the witness's memory that we believe we have a document or some other information that contradicts what she's saying, then we are allowed to cross on it. THE COURT: Okay. We'll take it as it comes, but we agree on the principles. I think the only question is -- I sustained the objection to admission of the photograph, because it's not clear to me that it's impeaching. As I said, if it's not impeaching, then it might be a Rule 16 issue; I wasn't entirely sure what you were trying to do with it. You're welcome to -- if there's some basis to show a photograph, to impeach something she suggested in her testimony, then you can do that. MR. EVERDELL: Yes. THE COURT: Okay. MR. EVERDELL: Understood. MR. ROHRBACH: The government agrees, your Honor. The issue with that particular photograph, setting aside the fact SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00017620",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 11 of 264 417 LC1VMAX1",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The government also doesn't agree with the defense's broad statement that anything that goes to this witness's memory is a noncollateral matter. It's hard for us to know now exactly what they plan to do. The government thinks we should take that as it comes. But I think there's sort of broad agreement about the general principles here, your Honor. MR. EVERDELL: If there's broad agreement, your Honor, then there shouldn't be objections. If we have an issue with the witness's memory that we believe we have a document or some other information that contradicts what she's saying, then we are allowed to cross on it. THE COURT: Okay. We'll take it as it comes, but we agree on the principles. I think the only question is -- I sustained the objection to admission of the photograph, because it's not clear to me that it's impeaching. As I said, if it's not impeaching, then it might be a Rule 16 issue; I wasn't entirely sure what you were trying to do with it. You're welcome to -- if there's some basis to show a photograph, to impeach something she suggested in her testimony, then you can do that. MR. EVERDELL: Yes. THE COURT: Okay. MR. EVERDELL: Understood. MR. ROHRBACH: The government agrees, your Honor. The issue with that particular photograph, setting aside the fact",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00017620",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "MR. EVERDELL",
      "MR. ROHRBACH"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "745",
      "DOJ-OGR-00017620"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}