mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00017606.json

{
  "document_metadata": {
    "page_number": "244",
    "document_number": "743",
    "date": "08/10/22",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 743 Filed 08/10/22 Page 244 of 247 403 LBUCmax7\n1 each of the witnesses in issue such that the rule would allow prior consistent statements? I suppose the question is whether\n2 a particular statement being offered is consistent with the testimony, but I don't know that it has to be with respect to\n3 cross. It seems to me it has to be with respect to direct,\n4 because you asked the jury essentially to evaluate all of the witnesses' testimony as being motivated by memory issues,\n5 manipulation, and monetary motivations.\n6\n7 So I think that's the issue. I'll certainly think about that question and then consider the -- I think this is a\n8 useful example. I'm happy to hear -- I mean, it strikes me that's right, but I'm happy to hear why that wouldn't be right.\n9\n10 MS. STERNHEIM: I'm not suggesting, I'm just asking for an opportunity to dovetail her testimony with the statement\n11 that is the support for the next witness's testimony. I'm not seeking to preclude, I'm just asking for an opportunity on the\n12 issue of prior consistency.\n13\n14 THE COURT: We can pick this up in the morning, but the government made a specific proffer of anticipated testimony\n15 based on direct testimony, which is to say -- I mean, when the witness is testifying, you could say that's not consistent with\n16 the prior testimony. Is that what you want to do?\n17\n18 MS. STERNHEIM: I'm just asking for an opportunity to compare it. I am not standing here saying I'm opposing it.\n19\n20 THE COURT: I got it. So it's not about the cross of\n21\n22 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n23 DOJ-OGR-00017606",
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      "content": "Case 1:20-cr-00330-PAE Document 743 Filed 08/10/22 Page 244 of 247 403 LBUCmax7",
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      "content": "each of the witnesses in issue such that the rule would allow prior consistent statements? I suppose the question is whether\na particular statement being offered is consistent with the testimony, but I don't know that it has to be with respect to\ncross. It seems to me it has to be with respect to direct,\nbecause you asked the jury essentially to evaluate all of the witnesses' testimony as being motivated by memory issues,\nmanipulation, and monetary motivations.\n\nSo I think that's the issue. I'll certainly think about that question and then consider the -- I think this is a\nuseful example. I'm happy to hear -- I mean, it strikes me that's right, but I'm happy to hear why that wouldn't be right.\n\nMS. STERNHEIM: I'm not suggesting, I'm just asking for an opportunity to dovetail her testimony with the statement\nthat is the support for the next witness's testimony. I'm not seeking to preclude, I'm just asking for an opportunity on the\nissue of prior consistency.\n\nTHE COURT: We can pick this up in the morning, but the government made a specific proffer of anticipated testimony\nbased on direct testimony, which is to say -- I mean, when the witness is testifying, you could say that's not consistent with\nthe prior testimony. Is that what you want to do?\n\nMS. STERNHEIM: I'm just asking for an opportunity to compare it. I am not standing here saying I'm opposing it.\n\nTHE COURT: I got it. So it's not about the cross of",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00017606",
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  ],
  "entities": {
    "people": [
      "MS. STERNHEIM"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "743",
      "DOJ-OGR-00017606"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a discussion between the court and MS. STERNHEIM about the admissibility of prior consistent statements. The transcript is from a court case with the reference number 1:20-cr-00330-PAE, document 743."
}