mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00012030.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 LC1VMAX1 1 MR. EVERDELL: Her memory about anything to do with this time period is not a collateral matter; she is a central witness to this case. 2 THE COURT: Well, again, I don't adopt that broad statement. But to the extent you are attempting to impeach -- 3 so you have something that contradicts what she testified to on the stand, then it's not a Rule 16 issue, I doubt it's a 613 -- 4 a 608 issue. We may have to deal with 613 questions and what it is that we're looking at. 5 MR. EVERDELL: Again, it's also not a 608 issue, I'd say, your Honor, because that rule deals with conduct. 6 THE COURT: I said it's not a 608 issue. 7 MR. EVERDELL: Yes. Okay. I agree with you. 8 MR. ROHRBACH: I'm a little confused, your Honor. 9 I think we're agreeing that, as your Honor said, if it's offered for impeachment with a proper basis for impeachment and it's not about a collateral matter, then they didn't have to disclose it in Rule 16. If it's to advance the defense case, whether in the government's case or in the defense case, then it should have been disclosed in Rule 16. 10 There are things that the defense might expect to offer for impeachment, but that might be impeachment about a collateral matter or might be impeachment, but is not, in fact, based on a contradiction or some other proper theory of impeachment, in which case it is not an admissible exhibit. 11 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00012030",
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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 this time period is not a collateral matter; she is a central witness to this case. 2 THE COURT: Well, again, I don't adopt that broad statement. But to the extent you are attempting to impeach -- 3 so you have something that contradicts what she testified to on the stand, then it's not a Rule 16 issue, I doubt it's a 613 -- 4 a 608 issue. We may have to deal with 613 questions and what it is that we're looking at. 5 MR. EVERDELL: Again, it's also not a 608 issue, I'd say, your Honor, because that rule deals with conduct. 6 THE COURT: I said it's not a 608 issue. 7 MR. EVERDELL: Yes. Okay. I agree with you. 8 MR. ROHRBACH: I'm a little confused, your Honor. 9 I think we're agreeing that, as your Honor said, if it's offered for impeachment with a proper basis for impeachment and it's not about a collateral matter, then they didn't have to disclose it in Rule 16. If it's to advance the defense case, whether in the government's case or in the defense case, then it should have been disclosed in Rule 16. 10 There are things that the defense might expect to offer for impeachment, but that might be impeachment about a collateral matter or might be impeachment, but is not, in fact, based on a contradiction or some other proper theory of impeachment, in which case it is not an admissible exhibit.",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00012030",
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  "entities": {
    "people": [
      "MR. EVERDELL",
      "THE COURT",
      "MR. ROHRBACH"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "08/10/22"
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      "1:20-cr-00330-PAE",
      "745",
      "DOJ-OGR-00012030"
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}