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- "page_number": "27",
- "document_number": "749",
- "date": "08/10/22",
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- "full_text": "Case 1:20-cr-00330-PAE Document 749 Filed 08/10/22 Page 27 of 236 LBUCmax1 931 that has to be, from what I understand, witness 3. And so I don't think these should be admitted. I don't think they should be shown. If the government wants to introduce pictures of them, which I know is Government Exhibits 919 and 920, are photographs of the costumes outside of the box I believe, and the costumes themselves are Government Exhibit 53, the government wants to get the agent to describe certain items they found without exactly describing what they were, but have those items somewhat generally described and the photographs, you can describe taking a photograph of certain items, but not described in a way that the jury is going to know what they are. They can't be described as schoolgirl outfits. THE COURT: Right. I think it's consistent with what Ms. Moe said, which is basically some version of showing the items to the witness but not the jury, and just simply asking, without describing what they are, did you find these items during the search. MR. EVERDELL: As long as there is no description of the items and no showing them to the jury, I don't I think I have a problem. MS. MOE: Yes, your Honor, that's what I was trying to flag, a way of laying the foundation without putting before the jury prematurely what they are. If I'm permitted to lead the witness and direct her not to describe them, I'll just lay that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018128",
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- "content": "that has to be, from what I understand, witness 3. And so I don't think these should be admitted. I don't think they should be shown. If the government wants to introduce pictures of them, which I know is Government Exhibits 919 and 920, are photographs of the costumes outside of the box I believe, and the costumes themselves are Government Exhibit 53, the government wants to get the agent to describe certain items they found without exactly describing what they were, but have those items somewhat generally described and the photographs, you can describe taking a photograph of certain items, but not described in a way that the jury is going to know what they are. They can't be described as schoolgirl outfits.",
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- "content": "THE COURT: Right. I think it's consistent with what Ms. Moe said, which is basically some version of showing the items to the witness but not the jury, and just simply asking, without describing what they are, did you find these items during the search.",
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- "content": "MR. EVERDELL: As long as there is no description of the items and no showing them to the jury, I don't I think I have a problem.",
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- "content": "MS. MOE: Yes, your Honor, that's what I was trying to flag, a way of laying the foundation without putting before the jury prematurely what they are. If I'm permitted to lead the witness and direct her not to describe them, I'll just lay that",
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- "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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- "Ms. Moe",
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- "SOUTHERN DISTRICT REPORTERS, P.C."
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- "dates": [
- "08/10/22"
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- "1:20-cr-00330-PAE",
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