mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00016771.json

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    "page_number": "42",
    "document_number": "763",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-AJN Document 763 Filed 08/10/22 Page 42 of 197 LCHVMAX2 2583 1 these people which I will elicit. 2 You were aware of someone named Michelle in this case. 3 You were aware, for example, of this Michelle -- and I'm going 4 to have to use her full name, because we lost the anonymity 5 issue, but you're aware that there was a Michelle Healy who 6 worked in the office. You never spoke to Michelle Healy, did 7 you? So I would like to be able to do that. Under your 8 Honor's ruling, I believe, that's appropriate under the Watson 9 case. 10 THE COURT: Mr. Rohrbach. 11 MR. ROHRBACH: Your Honor, I disagree with almost 12 every premise of what Mr. Everdell just said. But the core 13 legal issue is one the Court has already analyzed which is the 14 Watson case is a Brady case. It doesn't stand for anything, as 15 the Second Circuit has held, about exactly what sorts of 16 evidence can and can't come in. The Court has explained that 17 the challenges of the thoroughness of the investigation can 18 come in in lots of ways, including cross-examination. The 19 defense counsel could and did ask Jane when she testified who 20 was in the room during the massages. They can put on evidence 21 of witnesses who they believe are the other people in the room. 22 But what they can't do is in their direct case, call a case 23 agent and say, You didn't take this investigative step; you 24 didn't take that investigative step. That is precisely the 25 challenge to the thoroughness of the investigation that's SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00016771",
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      "content": "1 these people which I will elicit. 2 You were aware of someone named Michelle in this case. 3 You were aware, for example, of this Michelle -- and I'm going 4 to have to use her full name, because we lost the anonymity 5 issue, but you're aware that there was a Michelle Healy who 6 worked in the office. You never spoke to Michelle Healy, did 7 you? So I would like to be able to do that. Under your 8 Honor's ruling, I believe, that's appropriate under the Watson 9 case. 10 THE COURT: Mr. Rohrbach. 11 MR. ROHRBACH: Your Honor, I disagree with almost 12 every premise of what Mr. Everdell just said. But the core 13 legal issue is one the Court has already analyzed which is the 14 Watson case is a Brady case. It doesn't stand for anything, as 15 the Second Circuit has held, about exactly what sorts of 16 evidence can and can't come in. The Court has explained that 17 the challenges of the thoroughness of the investigation can 18 come in in lots of ways, including cross-examination. The 19 defense counsel could and did ask Jane when she testified who 20 was in the room during the massages. They can put on evidence 21 of witnesses who they believe are the other people in the room. 22 But what they can't do is in their direct case, call a case 23 agent and say, You didn't take this investigative step; you 24 didn't take that investigative step. That is precisely the 25 challenge to the thoroughness of the investigation that's",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00016771",
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  "entities": {
    "people": [
      "Michelle Healy",
      "Mr. Everdell",
      "Mr. Rohrbach",
      "Jane"
    ],
    "organizations": [
      "Second Circuit",
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "08/10/22"
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    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "763",
      "DOJ-OGR-00016771"
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}