mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00012023.json

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    "page_number": "3",
    "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 3 of 264 409 LC1VMAX1\n1 And I still don't fully understand the photograph of the street that the witness read the line from saying, That's the address where we lived, how that's impeachment. That remains an open question in my mind.\n2\n3\n4\n5 But otherwise, Mr. Rohrbach, do you disagree with anything I've just said as to the state of the law?\n6\n7 MR. ROHRBACH: No, I think that's a correct statement of the law, your Honor.\n8\n9 The issue with the photograph is it wasn't established that that satisfied any of the theories of impeachment; and so if the defense is offering it for some other purpose, that purpose would be part of the defense's case-in-chief and, therefore, subject to Rule 16 or an attack on the witness's character for truthfulness, which would be barred by 608.\n10\n11\n12\n13\n14\n15 THE COURT: Right.\n16\n17 But the, I'll charitably call it, theory offered yesterday that anything that's not part of the case-in-chief somehow then falls under 608 as extrinsic, you've walked away from that.\n18\n19\n20 MR. ROHRBACH: Yes -- the theory really is that it has to satisfy some proper basis of impeachment for extrinsic evidence. So it's true that there are more than two paths, yes, your Honor.\n21\n22\n23\n24 THE COURT: All right. So just to get to the photograph, as I see it, the witness's testimony -- and tell\n25\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00012023",
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      "content": "And I still don't fully understand the photograph of the street that the witness read the line from saying, That's the address where we lived, how that's impeachment. That remains an open question in my mind.\nBut otherwise, Mr. Rohrbach, do you disagree with anything I've just said as to the state of the law?\nMR. ROHRBACH: No, I think that's a correct statement of the law, your Honor.\nThe issue with the photograph is it wasn't established that that satisfied any of the theories of impeachment; and so if the defense is offering it for some other purpose, that purpose would be part of the defense's case-in-chief and, therefore, subject to Rule 16 or an attack on the witness's character for truthfulness, which would be barred by 608.\nTHE COURT: Right.\nBut the, I'll charitably call it, theory offered yesterday that anything that's not part of the case-in-chief somehow then falls under 608 as extrinsic, you've walked away from that.\nMR. ROHRBACH: Yes -- the theory really is that it has to satisfy some proper basis of impeachment for extrinsic evidence. So it's true that there are more than two paths, yes, your Honor.\nTHE COURT: All right. So just to get to the photograph, as I see it, the witness's testimony -- and tell",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00012023",
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  "entities": {
    "people": [
      "Mr. Rohrbach"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "08/10/22"
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      "1:20-cr-00330-PAE",
      "745",
      "DOJ-OGR-00012023"
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