mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00018275.json

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    "page_number": "174",
    "document_number": "749",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 749 Filed 08/10/22 Page 174 of 236\nLC3KMAX6 Parkinson - Direct\n1 with my colleagues with that, but we would like an opportunity\n2 to brief that issue, your Honor.\n3 I understand the Court's concern.\n4 THE COURT: To brief it?\n5 MS. MOE: Yes, your Honor, to examine the case law\n6 that your Honor is referring to, consider it, and develop our\n7 argument potentially further.\n8 MS. COMEY: Your Honor, the thinking here is that the\n9 defense has had these exhibits for weeks, and we feel a bit\n10 sandbagged here because they could have raised this objection\n11 in their motions in limine and instead they did it after we had\n12 finished our direct of the witness who could have looked at\n13 these photographs.\n14 MS. MOE: In our view, part of the corroborating\n15 impact is that we didn't show these photographs to the victim\n16 and --\n17 THE COURT: I understand that. And I suppose you\n18 still can if you want to. You're welcome to brief it; I have\n19 no issue with that. There is a factual disjointedness between\n20 what you're seeking to enter and based on that testimony.\n21 MR. EVERDELL: Your Honor, if I could be heard on the\n22 issue of sandbagging: This was not sandbagging. If we had\n23 raised this at the motion in limine stage, the response would\n24 have quite rightly been, we're going to have to see what\n25 happens at trial, because it's their responsibility to lay a\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "LC3KMAX6 Parkinson - Direct",
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      "content": "1 with my colleagues with that, but we would like an opportunity\n2 to brief that issue, your Honor.\n3 I understand the Court's concern.\n4 THE COURT: To brief it?\n5 MS. MOE: Yes, your Honor, to examine the case law\n6 that your Honor is referring to, consider it, and develop our\n7 argument potentially further.\n8 MS. COMEY: Your Honor, the thinking here is that the\n9 defense has had these exhibits for weeks, and we feel a bit\n10 sandbagged here because they could have raised this objection\n11 in their motions in limine and instead they did it after we had\n12 finished our direct of the witness who could have looked at\n13 these photographs.\n14 MS. MOE: In our view, part of the corroborating\n15 impact is that we didn't show these photographs to the victim\n16 and --\n17 THE COURT: I understand that. And I suppose you\n18 still can if you want to. You're welcome to brief it; I have\n19 no issue with that. There is a factual disjointedness between\n20 what you're seeking to enter and based on that testimony.\n21 MR. EVERDELL: Your Honor, if I could be heard on the\n22 issue of sandbagging: This was not sandbagging. If we had\n23 raised this at the motion in limine stage, the response would\n24 have quite rightly been, we're going to have to see what\n25 happens at trial, because it's their responsibility to lay a",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "MS. MOE",
      "MS. COMEY",
      "MR. EVERDELL"
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    "dates": [
      "08/10/22"
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      "1:20-cr-00330-PAE",
      "749"
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