mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00017618.json

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    "page_number": "9",
    "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 9 of 264 LC1VMAX1 415\n\n1 The only question in any specific instance is is it impeaching,\n2 and is it a prior inconsistent statement. We have to deal with\n3 the rules around a prior inconsistent statement. It wasn't\n4 like you had deposition testimony. You had an FBI agent's\n5 write-up of notes which the witness was confronted with and\n6 said it was a mistake. Again, that wasn't moved in, but we can\n7 deal with that as it comes.\n8 There could be -- not here, but there could be 608\n9 issues if you're trying to use extrinsic evidence. If what we\n10 have is impeaching by contradiction, impeachment of what the\n11 witness testified to on the stand, then it's not going to be a\n12 608 issue.\n13 MR. EVERDELL: If we're impeaching the witness, yes,\n14 that's right. And I just want to address the issue of\n15 impeaching with extrinsic evidence, which I know the government\n16 has raised. That rule is -- and the cases they cite --\n17 THE COURT: I know you cited Rule 613. I hadn't\n18 understood their argument to be about 613.\n19 MR. EVERDELL: They raised in their papers the notion\n20 that you can't impeach -- or you can't use extrinsic evidence\n21 to impeach. But the rule there and the cases they've cited\n22 stand for the unremarkable proposition that you can't\n23 impeach -- or you can't use extrinsic evidence on a collateral\n24 matter.\n25 THE COURT: Correct.\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00017618",
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      "content": "1 The only question in any specific instance is is it impeaching,\n2 and is it a prior inconsistent statement. We have to deal with\n3 the rules around a prior inconsistent statement. It wasn't\n4 like you had deposition testimony. You had an FBI agent's\n5 write-up of notes which the witness was confronted with and\n6 said it was a mistake. Again, that wasn't moved in, but we can\n7 deal with that as it comes.\n8 There could be -- not here, but there could be 608\n9 issues if you're trying to use extrinsic evidence. If what we\n10 have is impeaching by contradiction, impeachment of what the\n11 witness testified to on the stand, then it's not going to be a\n12 608 issue.\n13 MR. EVERDELL: If we're impeaching the witness, yes,\n14 that's right. And I just want to address the issue of\n15 impeaching with extrinsic evidence, which I know the government\n16 has raised. That rule is -- and the cases they cite --\n17 THE COURT: I know you cited Rule 613. I hadn't\n18 understood their argument to be about 613.\n19 MR. EVERDELL: They raised in their papers the notion\n20 that you can't impeach -- or you can't use extrinsic evidence\n21 to impeach. But the rule there and the cases they've cited\n22 stand for the unremarkable proposition that you can't\n23 impeach -- or you can't use extrinsic evidence on a collateral\n24 matter.\n25 THE COURT: Correct.",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
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      "content": "DOJ-OGR-00017618",
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  "entities": {
    "people": [
      "MR. EVERDELL"
    ],
    "organizations": [
      "FBI",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "745",
      "DOJ-OGR-00017618"
    ]
  },
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}