DOJ-OGR-00012544.json 4.2 KB

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  3. "page_number": "30",
  4. "document_number": "749",
  5. "date": "08/10/22",
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  10. "full_text": "Case 1:20-cr-00330-PAE Document 749 Filed 08/10/22 Page 30 of 236 LBUCmax1 understanding is there is going to be several photographs, room by room, of what that this place looked like. So I don't think they've established a foundation for these photos, your Honor, and I don't think they will be able to because I don't think they have another witness who can do it, and I don't think they should be admitted. THE COURT: What are the exhibits numbers? MR. EVERDELL: It's everything in the 900 series, your Honor, minus the ones that are of the exterior, and I don't have those in my mind, but anything in the 900 series that is an image of the interior. And that also would include, your Honor, the massage rooms. I understand they want to introduce photographs of the massage room, interior. And case in point, your Honor, there are photographs on those walls in the massage room of nude females that we don't believe actually were there in the relevant time period. So this is the problem with introducing photographs from 2019 when it's 15 years after the fact. MS. MOE: Your Honor, as a threshold matter, I think Mr. Everdell was referring to testimony from Mr. Alessi about renovations. My understanding is that that testimony was about renovations in the Florida house and not the New York house. With respect to the point about a witness identifying the interior of the house as being consistent during the timeframe of the charged conspiracy, that witness is Jane. I SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00012544",
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  19. "content": "understanding is there is going to be several photographs, room by room, of what that this place looked like. So I don't think they've established a foundation for these photos, your Honor, and I don't think they will be able to because I don't think they have another witness who can do it, and I don't think they should be admitted. THE COURT: What are the exhibits numbers? MR. EVERDELL: It's everything in the 900 series, your Honor, minus the ones that are of the exterior, and I don't have those in my mind, but anything in the 900 series that is an image of the interior. And that also would include, your Honor, the massage rooms. I understand they want to introduce photographs of the massage room, interior. And case in point, your Honor, there are photographs on those walls in the massage room of nude females that we don't believe actually were there in the relevant time period. So this is the problem with introducing photographs from 2019 when it's 15 years after the fact. MS. MOE: Your Honor, as a threshold matter, I think Mr. Everdell was referring to testimony from Mr. Alessi about renovations. My understanding is that that testimony was about renovations in the Florida house and not the New York house. With respect to the point about a witness identifying the interior of the house as being consistent during the timeframe of the charged conspiracy, that witness is Jane. I",
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  33. "entities": {
  34. "people": [
  35. "MR. EVERDELL",
  36. "MS. MOE",
  37. "Mr. Alessi",
  38. "Jane"
  39. ],
  40. "organizations": [
  41. "SOUTHERN DISTRICT REPORTERS, P.C.",
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  44. "locations": [
  45. "Florida",
  46. "New York"
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  48. "dates": [
  49. "08/10/22",
  50. "2019"
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  52. "reference_numbers": [
  53. "1:20-cr-00330-PAE",
  54. "749",
  55. "900 series",
  56. "DOJ-OGR-00012544"
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