mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00014007.json

{
  "document_metadata": {
    "page_number": "148",
    "document_number": "761",
    "date": "08/10/22",
    "document_type": "court transcript",
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  "full_text": "Case 1:20-cr-00330-PAE Document 761 Filed 08/10/22 Page 148 of 246 2443 LCGCmax4 Loftus - direct said no and we have a witness who says otherwise. To let it just stand is only her statement, which we have the ability to contest. MR. ROHRBACH: That would only be true if it went to bias and motive, which it doesn't for the reasons I've explained. As the Court is aware, I think we had this conversation at a sidebar during Kate's testimony when Ms. Sternheim had this declaration and we all agreed this is a collateral matter at that time. MS. STERNHEIM: Judge, collateral during the testimony of that witness. Having another witness to counter what that witness says elevates it to another category. MR. ROHRBACH: It's impeachment with extrinsic evidence, whether that extrinsic evidence is a declaration or live testimony by a witness. THE COURT: It's not just the impeachment, it's not just the question of did she say it or not. Although, there is that impeachment embedded in it. But there is just the testimony itself and the question is whether that's relevant evidence of bias or motive; right? Isn't that the analysis? MR. ROHRBACH: I didn't understand the defense to be offering this as affirmative evidence of bias or motive, just as impeachment for those reasons. The defense has never turned this over in Rule 16 discovery, for example, which they would do if it was part of their case in chief because they were SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014007",
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      "type": "printed",
      "content": "said no and we have a witness who says otherwise. To let it just stand is only her statement, which we have the ability to contest. MR. ROHRBACH: That would only be true if it went to bias and motive, which it doesn't for the reasons I've explained. As the Court is aware, I think we had this conversation at a sidebar during Kate's testimony when Ms. Sternheim had this declaration and we all agreed this is a collateral matter at that time. MS. STERNHEIM: Judge, collateral during the testimony of that witness. Having another witness to counter what that witness says elevates it to another category. MR. ROHRBACH: It's impeachment with extrinsic evidence, whether that extrinsic evidence is a declaration or live testimony by a witness. THE COURT: It's not just the impeachment, it's not just the question of did she say it or not. Although, there is that impeachment embedded in it. But there is just the testimony itself and the question is whether that's relevant evidence of bias or motive; right? Isn't that the analysis? MR. ROHRBACH: I didn't understand the defense to be offering this as affirmative evidence of bias or motive, just as impeachment for those reasons. The defense has never turned this over in Rule 16 discovery, for example, which they would do if it was part of their case in chief because they were",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00014007",
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  "entities": {
    "people": [
      "MR. ROHRBACH",
      "MS. STERNHEIM",
      "Kate"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
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      "1:20-cr-00330-PAE",
      "761",
      "DOJ-OGR-00014007"
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}