mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00012006.json

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    "page_number": "234",
    "document_number": "743",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 743 Filed 08/10/22 Page 234 of 247 393 LBUCmax7\n\n1 introduced, it's in violation of Rule 16. I think to the\n2 extent there are other exhibits that the defense intends to\n3 offer that have not already been produced to us, we would ask\n4 that the Court order that they make those productions\n5 forthwith.\n6 MS. MENNINGER: Your Honor, we have a very different\n7 view of Rule 16. If it is an impeachment document, it is not\n8 covered by the rule. We will brief this tonight if your Honor\n9 would like. I have a very different view, apparently, than\n10 Ms. Comey.\n11 MS. COMEY: Your Honor, we do not believe that any\n12 prior inconsistent statements that would be admissible --\n13 THE COURT: It's not a prior inconsistent statement.\n14 MS. COMEY: Exactly, your Honor. Nothing else is\n15 admissible as impeachment by my reading of the rules of\n16 evidence.\n17 MS. MENNINGER: Your Honor, anything that goes to the\n18 witness's memory, bias, motive, all of those are impeachment\n19 materials. Impeachment is not limited to prior inconsistent\n20 statements. That's just not the state of the law.\n21 THE COURT: You can brief it. So if the witness\n22 testifies I live in a blue house and you go out tonight and\n23 take a photograph of the house and it's a red house --\n24 MS. MENNINGER: Yes, your Honor.\n25 THE COURT: -- and you want to introduce a photograph\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00012006",
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      "content": "1 introduced, it's in violation of Rule 16. I think to the\n2 extent there are other exhibits that the defense intends to\n3 offer that have not already been produced to us, we would ask\n4 that the Court order that they make those productions\n5 forthwith.\n6 MS. MENNINGER: Your Honor, we have a very different\n7 view of Rule 16. If it is an impeachment document, it is not\n8 covered by the rule. We will brief this tonight if your Honor\n9 would like. I have a very different view, apparently, than\n10 Ms. Comey.\n11 MS. COMEY: Your Honor, we do not believe that any\n12 prior inconsistent statements that would be admissible --\n13 THE COURT: It's not a prior inconsistent statement.\n14 MS. COMEY: Exactly, your Honor. Nothing else is\n15 admissible as impeachment by my reading of the rules of\n16 evidence.\n17 MS. MENNINGER: Your Honor, anything that goes to the\n18 witness's memory, bias, motive, all of those are impeachment\n19 materials. Impeachment is not limited to prior inconsistent\n20 statements. That's just not the state of the law.\n21 THE COURT: You can brief it. So if the witness\n22 testifies I live in a blue house and you go out tonight and\n23 take a photograph of the house and it's a red house --\n24 MS. MENNINGER: Yes, your Honor.\n25 THE COURT: -- and you want to introduce a photograph",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
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      "content": "DOJ-OGR-00012006",
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  "entities": {
    "people": [
      "MS. MENNINGER",
      "MS. COMEY"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 743",
      "DOJ-OGR-00012006"
    ]
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}