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    "page_number": "7",
    "document_number": "745",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 7 of 264 LC1VMAX1 413\n\n1 and those were introduced.\n2 If we hypothetically had photos of that same island\n3 before those houses were built, we don't, but if we did and we\n4 wanted to introduce those through Larry Visoski, again, that\n5 would be affirmative defense in the defense case-in-chief\n6 introduced through the government's witness. That would be\n7 Rule 16 which we'd have to disclose ahead of time.\n8 THE COURT: Right.\n9 MR. EVERDELL: Now, what we are talking about here is\n10 what Witness 1, what Jane, remembers about the childhood, about\n11 these events; it's about her recollection of everything, and\n12 that is critical to the case. So misremembering details,\n13 misremembering where she lived, not being able to recognize a\n14 house, that all goes to her credibility as a witness, her\n15 believability, any contradiction.\n16 This is central to the case. Her memory of every\n17 single detail of her childhood is central to the case, and that\n18 is not case-in-chief material. That is, if she testifies to\n19 something and we think we have something that contradicts what\n20 she just said, like a photograph of her -- of a place where she\n21 lived as a child, but she didn't seem to remember, that's\n22 impeachment material. And we don't know if we're going to use\n23 that until she says on the stand what she says on the stand.\n24 We have it ready to go in case she says that, and she did in\n25 this case, and so that's why we were able to use it or try to\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00012027",
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      "content": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 7 of 264 LC1VMAX1 413",
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      "content": "1 and those were introduced.\n2 If we hypothetically had photos of that same island\n3 before those houses were built, we don't, but if we did and we\n4 wanted to introduce those through Larry Visoski, again, that\n5 would be affirmative defense in the defense case-in-chief\n6 introduced through the government's witness. That would be\n7 Rule 16 which we'd have to disclose ahead of time.\n8 THE COURT: Right.\n9 MR. EVERDELL: Now, what we are talking about here is\n10 what Witness 1, what Jane, remembers about the childhood, about\n11 these events; it's about her recollection of everything, and\n12 that is critical to the case. So misremembering details,\n13 misremembering where she lived, not being able to recognize a\n14 house, that all goes to her credibility as a witness, her\n15 believability, any contradiction.\n16 This is central to the case. Her memory of every\n17 single detail of her childhood is central to the case, and that\n18 is not case-in-chief material. That is, if she testifies to\n19 something and we think we have something that contradicts what\n20 she just said, like a photograph of her -- of a place where she\n21 lived as a child, but she didn't seem to remember, that's\n22 impeachment material. And we don't know if we're going to use\n23 that until she says on the stand what she says on the stand.\n24 We have it ready to go in case she says that, and she did in\n25 this case, and so that's why we were able to use it or try to",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
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      "content": "DOJ-OGR-00012027",
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  "entities": {
    "people": [
      "Larry Visoski",
      "Jane",
      "Witness 1",
      "MR. EVERDELL"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "745",
      "DOJ-OGR-00012027"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}