DOJ-OGR-00018875.json 4.1 KB

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  3. "page_number": "13",
  4. "document_number": "755",
  5. "date": "08/10/22",
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  10. "full_text": "Case 1:20-cr-00330-PAE Document 755 Filed 08/10/22 Page 13 of 262 1718 LC8Cmax1\n1 business record?\n2 MS. STERNHEIM: That is correct, Judge.\n3 THE COURT: Mr. Rohrbach.\n4 MR. ROHRBACH: I wasn't planning to ask Ms. Gill this,\n5 but I think she would say that Mar-a-Lago retains these records\n6 in case there is some kind of dispute involving the insurance\n7 company and its employees. But Mar-a-Lago does retain these\n8 records because, in order to hire, retain, and protect its\n9 employees, they presumably make sure they're offered insurance.\n10 And I'll just note, your Honor, that the exhibit and\n11 Government Exhibit 824 are not just the benefit application\n12 forms, but fax transmittal cover sheets from Mar-a-Lago which\n13 indicates that Mar-a-Lago is doing the work of processing and\n14 sending out these applications.\n15 MS. STERNHEIM: But it still contains hearsay\n16 information, the source of which we do not know. It is not\n17 part of the business of Mar-a-Lago, even though it does have\n18 employees and may offer it insurance, the fact that it is kept\n19 in their files does not deem it a business record.\n20 THE COURT: I think I'll have to hear the testimony,\n21 the foundation for the business record to determine whether\n22 it's sufficient under the rule.\n23 Do you have any authority, Ms. Sternheim?\n24 I would say, just intuitively, I would think that\n25 employers who provide insurance to employees who have a set of\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00018875",
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  14. "content": "Case 1:20-cr-00330-PAE Document 755 Filed 08/10/22 Page 13 of 262 1718 LC8Cmax1",
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  19. "content": "1 business record?\n2 MS. STERNHEIM: That is correct, Judge.\n3 THE COURT: Mr. Rohrbach.\n4 MR. ROHRBACH: I wasn't planning to ask Ms. Gill this,\n5 but I think she would say that Mar-a-Lago retains these records\n6 in case there is some kind of dispute involving the insurance\n7 company and its employees. But Mar-a-Lago does retain these\n8 records because, in order to hire, retain, and protect its\n9 employees, they presumably make sure they're offered insurance.\n10 And I'll just note, your Honor, that the exhibit and\n11 Government Exhibit 824 are not just the benefit application\n12 forms, but fax transmittal cover sheets from Mar-a-Lago which\n13 indicates that Mar-a-Lago is doing the work of processing and\n14 sending out these applications.\n15 MS. STERNHEIM: But it still contains hearsay\n16 information, the source of which we do not know. It is not\n17 part of the business of Mar-a-Lago, even though it does have\n18 employees and may offer it insurance, the fact that it is kept\n19 in their files does not deem it a business record.\n20 THE COURT: I think I'll have to hear the testimony,\n21 the foundation for the business record to determine whether\n22 it's sufficient under the rule.\n23 Do you have any authority, Ms. Sternheim?\n24 I would say, just intuitively, I would think that\n25 employers who provide insurance to employees who have a set of",
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  24. "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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  29. "content": "DOJ-OGR-00018875",
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  33. "entities": {
  34. "people": [
  35. "Ms. Sternheim",
  36. "Mr. Rohrbach",
  37. "Ms. Gill"
  38. ],
  39. "organizations": [
  40. "Mar-a-Lago",
  41. "SOUTHERN DISTRICT REPORTERS, P.C."
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  44. "dates": [
  45. "08/10/22"
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  48. "1:20-cr-00330-PAE",
  49. "755",
  50. "824",
  51. "DOJ-OGR-00018875"
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