mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00013597.json

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    "page_number": "6",
    "document_number": "759",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 759 Filed 08/10/22 Page 6 of 267 2033 LCACmax1\n\n1 MR. PAGLIUCA: Yes. So we are objecting to the late\n2 endorsement and the calling of the witness, first on simply\n3 disclosure issues, but second, I'm unclear of the relevance,\n4 given the lack of any, I'll call it, tying to any actual\n5 testimony.\n\n6 We're going to get a DMV record, as I understand it, from this witness that no one else who has testified has ever\n8 done any comparator between whatever is in the DMV record and\n9 either photographs or other information about the witness that\n10 Mr. Rodgers talked about. So I don't think there has been a\n11 linkup for relevance purposes.\n\n12 So we object on the basis of relevance to this witness\n13 being called, as well.\n\n14 THE COURT: Who will handle this one?\n15 MS. MOE: Yes, your Honor. This exhibit and this\n16 evidence is directly responsive to an issue raised by the\n17 defense in their cross examination of both pilots in this case.\n18 As the Court may recall, defense counsel suggested\n19 that the Jane in the records in the 1990s could potentially be\n20 the person with the first name Jane from the 2000s. We have\n21 produced in discovery, and is nontesting witness materials,\n22 ample material that makes it clear that could not possibly --\n23 and in response to the suggestion that it might be this\n24 different person, we now need to clarify the record on that.\n\n25 As defense counsel knows, the second Jane from the\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00013597",
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      "content": "Case 1:20-cr-00330-PAE Document 759 Filed 08/10/22 Page 6 of 267 2033 LCACmax1",
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      "content": "1 MR. PAGLIUCA: Yes. So we are objecting to the late endorsement and the calling of the witness, first on simply disclosure issues, but second, I'm unclear of the relevance, given the lack of any, I'll call it, tying to any actual testimony.",
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      "content": "6 We're going to get a DMV record, as I understand it, from this witness that no one else who has testified has ever done any comparator between whatever is in the DMV record and either photographs or other information about the witness that Mr. Rodgers talked about. So I don't think there has been a linkup for relevance purposes.",
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    {
      "type": "printed",
      "content": "12 So we object on the basis of relevance to this witness being called, as well.",
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      "type": "printed",
      "content": "14 THE COURT: Who will handle this one?",
      "position": "main content"
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    {
      "type": "printed",
      "content": "15 MS. MOE: Yes, your Honor. This exhibit and this evidence is directly responsive to an issue raised by the defense in their cross examination of both pilots in this case.",
      "position": "main content"
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    {
      "type": "printed",
      "content": "18 As the Court may recall, defense counsel suggested that the Jane in the records in the 1990s could potentially be the person with the first name Jane from the 2000s. We have produced in discovery, and is nontesting witness materials, ample material that makes it clear that could not possibly -- and in response to the suggestion that it might be this different person, we now need to clarify the record on that.",
      "position": "main content"
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    {
      "type": "printed",
      "content": "25 As defense counsel knows, the second Jane from the",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00013597",
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  "entities": {
    "people": [
      "MR. PAGLIUCA",
      "MR. RODGERS",
      "MS. MOE"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22",
      "1990s",
      "2000s"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "759",
      "DOJ-OGR-00013597"
    ]
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