mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00012025.json

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  "full_text": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 5 of 264 411 LC1VMAX1\n\n1 problems, but certainly wasn't directly impeaching of her testimony.\n2\n3 MR. EVERDELL: Your Honor, I'm sorry. I just -- see if we could back up.\n4\n5 Have we moved beyond the Rule 16 issue at this point and we're just talking about --\n6\n7 THE COURT: Well, if it's impeaching, then there's not a Rule 16 issue. As I sit here, I don't know -- I don't see that it's impeaching; so that if it's not impeaching, I'm not sure what you're doing with it and it may be a Rule 16 issue.\n8\n9\n10 MR. EVERDELL: If I can address that, your Honor, because I think we disagree with what the state of the law is. I think there's some disagreement on the courts about whether or not if the defense is going to introduce something or talk about something on cross-examination, whether that is considered a Rule 16 document.\n11\n12\n13\n14\n15 So what I understand the case law to be, your Honor, is that they are trying to deal with the issue of where the defense is trying to introduce affirmative proof in its own case through the government's own witnesses.\n16\n17\n18 THE COURT: For sure. Which is, let's face it, usually what happens. There's often not a defense case. Both cross-examination and impeachment testimony, as well as affirmative evidence, comes in through cross-examination.\n19\n20\n21 So I think the cases that say there's not a clear\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n\nDOJ-OGR-00012025",
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      "content": "1 problems, but certainly wasn't directly impeaching of her testimony.\n2\n3 MR. EVERDELL: Your Honor, I'm sorry. I just -- see if we could back up.\n4\n5 Have we moved beyond the Rule 16 issue at this point and we're just talking about --\n6\n7 THE COURT: Well, if it's impeaching, then there's not a Rule 16 issue. As I sit here, I don't know -- I don't see that it's impeaching; so that if it's not impeaching, I'm not sure what you're doing with it and it may be a Rule 16 issue.\n8\n9\n10 MR. EVERDELL: If I can address that, your Honor, because I think we disagree with what the state of the law is. I think there's some disagreement on the courts about whether or not if the defense is going to introduce something or talk about something on cross-examination, whether that is considered a Rule 16 document.\n11\n12\n13\n14\n15 So what I understand the case law to be, your Honor, is that they are trying to deal with the issue of where the defense is trying to introduce affirmative proof in its own case through the government's own witnesses.\n16\n17\n18 THE COURT: For sure. Which is, let's face it, usually what happens. There's often not a defense case. Both cross-examination and impeachment testimony, as well as affirmative evidence, comes in through cross-examination.\n19\n20\n21 So I think the cases that say there's not a clear",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00012025",
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    "dates": [
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      "745",
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