mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00017619.json

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    "page_number": "10",
    "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 10 of 264 416\n\n1 MR. EVERDELL: Her memory about anything to do with\n2 this time period is not a collateral matter; she is a central\n3 witness to this case.\n4 THE COURT: Well, again, I don't adopt that broad\n5 statement. But to the extent you are attempting to impeach --\n6 so you have something that contradicts what she testified to on\n7 the stand, then it's not a Rule 16 issue, I doubt it's a 613 --\n8 a 608 issue. We may have to deal with 613 questions and what\n9 it is that we're looking at.\n10 MR. EVERDELL: Again, it's also not a 608 issue, I'd\n11 say, your Honor, because that rule deals with conduct.\n12 THE COURT: I said it's not a 608 issue.\n13 MR. EVERDELL: Yes. Okay. I agree with you.\n14 MR. ROHRBACH: I'm a little confused, your Honor.\n15 I think we're agreeing that, as your Honor said, if\n16 it's offered for impeachment with a proper basis for\n17 impeachment and it's not about a collateral matter, then they\n18 didn't have to disclose it in Rule 16. If it's to advance the\n19 defense case, whether in the government's case or in the\n20 defense case, then it should have been disclosed in Rule 16.\n21 There are things that the defense might expect to\n22 offer for impeachment, but that might be impeachment about a\n23 collateral matter or might be impeachment, but is not, in fact,\n24 based on a contradiction or some other proper theory of\n25 impeachment, in which case it is not an admissible exhibit.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 10 of 264 416",
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      "content": "1 MR. EVERDELL: Her memory about anything to do with\n2 this time period is not a collateral matter; she is a central\n3 witness to this case.\n4 THE COURT: Well, again, I don't adopt that broad\n5 statement. But to the extent you are attempting to impeach --\n6 so you have something that contradicts what she testified to on\n7 the stand, then it's not a Rule 16 issue, I doubt it's a 613 --\n8 a 608 issue. We may have to deal with 613 questions and what\n9 it is that we're looking at.\n10 MR. EVERDELL: Again, it's also not a 608 issue, I'd\n11 say, your Honor, because that rule deals with conduct.\n12 THE COURT: I said it's not a 608 issue.\n13 MR. EVERDELL: Yes. Okay. I agree with you.\n14 MR. ROHRBACH: I'm a little confused, your Honor.\n15 I think we're agreeing that, as your Honor said, if\n16 it's offered for impeachment with a proper basis for\n17 impeachment and it's not about a collateral matter, then they\n18 didn't have to disclose it in Rule 16. If it's to advance the\n19 defense case, whether in the government's case or in the\n20 defense case, then it should have been disclosed in Rule 16.\n21 There are things that the defense might expect to\n22 offer for impeachment, but that might be impeachment about a\n23 collateral matter or might be impeachment, but is not, in fact,\n24 based on a contradiction or some other proper theory of\n25 impeachment, in which case it is not an admissible exhibit.",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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  "entities": {
    "people": [
      "MR. EVERDELL",
      "THE COURT",
      "MR. ROHRBACH"
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      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "08/10/22"
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      "745",
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      "608",
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      "212-805-0300"
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