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- "page_number": "157",
- "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 157 of 197 2698 LCHCmax5\n\n1 THE COURT: And that's in the record; right?\n2 MR. EVERDELL: We're going to have to add that as part\n3 of the stipulation. We have the land registry records for that\n4 residence now, as well, showing her ownership of that\n5 residence, but we still want to be able to counter what I think\n6 is an incorrect inference to the jury that she wasn't there.\n7 Yes, I understand there is a deposition where she made an\n8 offhand reference and got the years wrong, but we now have a\n9 witness who can actually say what we believe to be true, which\n10 is that she wasn't living there either until she owned it.\n11 THE COURT: And sometimes details are off.\n12 MR. EVERDELL: And she may have in that deposition\n13 gotten the place wrong because she had the prior place in\n14 London, and Stanhope Mews was the name of the street. At that\n15 time in '92, '93, she owned that place. So she may have gotten\n16 the place wrong in the deposition.\n17 So what I think it sets up is a misleading --\n18 factually misleading impression for the jury based on an\n19 offhand deposition transcript quote, one line from a 2019\n20 deposition where it's not exactly clear which residence she may\n21 be referring to in the first place.\n22 And this is an important point for the defense, your\n23 Honor. We feel like --\n24 THE COURT: Let me just make sure, because all of\n25 this, all of this is impeachment of a witness who says that\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00016886",
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- "content": "1 THE COURT: And that's in the record; right?\n2 MR. EVERDELL: We're going to have to add that as part\n3 of the stipulation. We have the land registry records for that\n4 residence now, as well, showing her ownership of that\n5 residence, but we still want to be able to counter what I think\n6 is an incorrect inference to the jury that she wasn't there.\n7 Yes, I understand there is a deposition where she made an\n8 offhand reference and got the years wrong, but we now have a\n9 witness who can actually say what we believe to be true, which\n10 is that she wasn't living there either until she owned it.\n11 THE COURT: And sometimes details are off.\n12 MR. EVERDELL: And she may have in that deposition\n13 gotten the place wrong because she had the prior place in\n14 London, and Stanhope Mews was the name of the street. At that\n15 time in '92, '93, she owned that place. So she may have gotten\n16 the place wrong in the deposition.\n17 So what I think it sets up is a misleading --\n18 factually misleading impression for the jury based on an\n19 offhand deposition transcript quote, one line from a 2019\n20 deposition where it's not exactly clear which residence she may\n21 be referring to in the first place.\n22 And this is an important point for the defense, your\n23 Honor. We feel like --\n24 THE COURT: Let me just make sure, because all of\n25 this, all of this is impeachment of a witness who says that",
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- "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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- "content": "DOJ-OGR-00016886",
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- "entities": {
- "people": [
- "MR. EVERDELL"
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- "organizations": [
- "SOUTHERN DISTRICT REPORTERS, P.C."
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- "locations": [
- "London",
- "Stanhope Mews"
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- "dates": [
- "08/10/22",
- "2019",
- "'92",
- "'93"
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- "1:20-cr-00330-AJN",
- "763",
- "DOJ-OGR-00016886"
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