mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00017616.json

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    "page_number": "7",
    "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 7 of 264 LC1VMAX1 413\n\n1 and those were introduced.\n\n2 If we hypothetically had photos of that same island\n3 before those houses were built, we don't, but if we did and we\n4 wanted to introduce those through Larry Visoski, again, that\n5 would be affirmative defense in the defense case-in-chief\n6 introduced through the government's witness. That would be\n7 Rule 16 which we'd have to disclose ahead of time.\n8\n9 THE COURT: Right.\n10 MR. EVERDELL: Now, what we are talking about here is\n11 what Witness 1, what Jane, remembers about the childhood, about\n12 these events; it's about her recollection of everything, and\n13 that is critical to the case. So misremembering details,\n14 misremembering where she lived, not being able to recognize a\n15 house, that all goes to her credibility as a witness, her\n16 believability, any contradiction.\n17 This is central to the case. Her memory of every\n18 single detail of her childhood is central to the case, and that\n19 is not case-in-chief material. That is, if she testifies to\n20 something and we think we have something that contradicts what\n21 she just said, like a photograph of her -- of a place where she\n22 lived as a child, but she didn't seem to remember, that's\n23 impeachment material. And we don't know if we're going to use\n24 that until she says on the stand what she says on the stand.\n25 We have it ready to go in case she says that, and she did in\n26 this case, and so that's why we were able to use it or try to\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00017616",
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      "content": "and those were introduced. If we hypothetically had photos of that same island before those houses were built, we don't, but if we did and we wanted to introduce those through Larry Visoski, again, that would be affirmative defense in the defense case-in-chief introduced through the government's witness. That would be Rule 16 which we'd have to disclose ahead of time. THE COURT: Right. MR. EVERDELL: Now, what we are talking about here is what Witness 1, what Jane, remembers about the childhood, about these events; it's about her recollection of everything, and that is critical to the case. So misremembering details, misremembering where she lived, not being able to recognize a house, that all goes to her credibility as a witness, her believability, any contradiction. This is central to the case. Her memory of every single detail of her childhood is central to the case, and that is not case-in-chief material. That is, if she testifies to something and we think we have something that contradicts what she just said, like a photograph of her -- of a place where she lived as a child, but she didn't seem to remember, that's impeachment material. And we don't know if we're going to use that until she says on the stand what she says on the stand. We have it ready to go in case she says that, and she did in this case, and so that's why we were able to use it or try to",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00017616",
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  "entities": {
    "people": [
      "Larry Visoski",
      "Jane",
      "Witness 1",
      "MR. EVERDELL"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "745",
      "DOJ-OGR-00017616"
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