mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00012688.json

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    "page_number": "174",
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    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 749 Filed 08/10/22 Page 174 of 236 LC3KMAX6 Parkinson - Direct with my colleagues with that, but we would like an opportunity to brief that issue, your Honor. I understand the Court's concern. THE COURT: To brief it? MS. MOE: Yes, your Honor, to examine the case law that your Honor is referring to, consider it, and develop our argument potentially further. MS. COMEY: Your Honor, the thinking here is that the defense has had these exhibits for weeks, and we feel a bit sandbagged here because they could have raised this objection in their motions in limine and instead they did it after we had finished our direct of the witness who could have looked at these photographs. MS. MOE: In our view, part of the corroborating impact is that we didn't show these photographs to the victim and -- THE COURT: I understand that. And I suppose you still can if you want to. You're welcome to brief it; I have no issue with that. There is a factual disjointedness between what you're seeking to enter and based on that testimony. MR. EVERDELL: Your Honor, if I could be heard on the issue of sandbagging: This was not sandbagging. If we had raised this at the motion in limine stage, the response would have quite rightly been, we're going to have to see what happens at trial, because it's their responsibility to lay a SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "LC3KMAX6 Parkinson - Direct",
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      "type": "printed",
      "content": "with my colleagues with that, but we would like an opportunity to brief that issue, your Honor. I understand the Court's concern. THE COURT: To brief it? MS. MOE: Yes, your Honor, to examine the case law that your Honor is referring to, consider it, and develop our argument potentially further. MS. COMEY: Your Honor, the thinking here is that the defense has had these exhibits for weeks, and we feel a bit sandbagged here because they could have raised this objection in their motions in limine and instead they did it after we had finished our direct of the witness who could have looked at these photographs. MS. MOE: In our view, part of the corroborating impact is that we didn't show these photographs to the victim and -- THE COURT: I understand that. And I suppose you still can if you want to. You're welcome to brief it; I have no issue with that. There is a factual disjointedness between what you're seeking to enter and based on that testimony. MR. EVERDELL: Your Honor, if I could be heard on the issue of sandbagging: This was not sandbagging. If we had raised this at the motion in limine stage, the response would have quite rightly been, we're going to have to see what happens at trial, because it's their responsibility to lay a",
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