mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00017617.json

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    "page_number": "8",
    "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 8 of 264 LC1VMAX1 414\n1 use it, to show that she doesn't have an accurate recollection.\n2 That is pure impeachment material.\n3 THE COURT: Up to the point where you said it contradicted what she said on the stand, you and I were in vigorous agreement.\n4\n5 MR. EVERDELL: Okay.\n6\n7 THE COURT: Okay.\n8 MR. EVERDELL: All right.\n9 Well, what I would say is that we can't -- no, this is not -- it's not as if we were going to introduce the photograph of her house in our case-in-chief. We are doing this -- we had it ready to be able to use it in case she said something that we believe was contradictory and contradicted by the photograph. So that's why we did not disclose it ahead of time, because we believed it to be impeachment material.\n10\n11 By the way, Judge, I'll just note for the record that when we sent our Rule 16 discovery several weeks ago to the government, we included a cover letter, which I'm happy to share with the Court --\n12\n13 THE COURT: I can imagine it reserved all your rights.\n14 And you can keep talking, but we remain in agreement.\n15 MR. EVERDELL: Okay. And it cited all the cases that we cited, and it said we do not consider impeachment material or refreshing material case-in-chief material.\n16\n17 THE COURT: It is true. I think, Mr. Rohrbach agrees.\n18\n19 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n20 DOJ-OGR-00017617",
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      "content": "1 use it, to show that she doesn't have an accurate recollection.\n2 That is pure impeachment material.\n3 THE COURT: Up to the point where you said it contradicted what she said on the stand, you and I were in vigorous agreement.\n4\n5 MR. EVERDELL: Okay.\n6\n7 THE COURT: Okay.\n8 MR. EVERDELL: All right.\n9 Well, what I would say is that we can't -- no, this is not -- it's not as if we were going to introduce the photograph of her house in our case-in-chief. We are doing this -- we had it ready to be able to use it in case she said something that we believe was contradictory and contradicted by the photograph. So that's why we did not disclose it ahead of time, because we believed it to be impeachment material.\n10\n11 By the way, Judge, I'll just note for the record that when we sent our Rule 16 discovery several weeks ago to the government, we included a cover letter, which I'm happy to share with the Court --\n12\n13 THE COURT: I can imagine it reserved all your rights.\n14 And you can keep talking, but we remain in agreement.\n15 MR. EVERDELL: Okay. And it cited all the cases that we cited, and it said we do not consider impeachment material or refreshing material case-in-chief material.\n16\n17 THE COURT: It is true. I think, Mr. Rohrbach agrees.",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00017617",
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  "entities": {
    "people": [
      "Mr. Everdell",
      "Mr. Rohrbach"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "08/10/22"
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      "1:20-cr-00330-PAE",
      "745",
      "DOJ-OGR-00017617"
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}