mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00014140.json

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    "page_number": "34",
    "document_number": "763",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 34 of 197 2575 LCFCmax1 investigation, but I specifically precluded direct evidence of failure of investigative techniques. MR. EVERDELL: I'm not saying an investigative technique per se, your Honor. I'm simply pointing out that evidence that a jury might expect to see, given we are in the modern era, is not present in front of them because of the age of the allegations. So I think this point through the agent clarifies the fact that these records don't exist anymore, they tried to get them, I think, and they didn't exist. It's not a particular technique, it's just highlighting the fact that, in a case of this age, there are records that have disappeared, phone records get deleted after a while, there is no such thing as geo location information, there weren't cellphones that had these things. So pointing it out to the agent is simply pointing out the absence of evidence because there wouldn't be anything in the record to argue that to the jury if I'm not allowed to put that in front of -- through this agent. I mean, there needs to be some explanation of the fact that I think this agent could provide that these people didn't have cellphones to their knowledge, so they wouldn't have had geo location information and that's why we don't have it in this case. MR. ROHRBACH: I'm a little confused why the defense wants to put this in, your Honor. We've had testimony in this case from a custodian and others about what recordkeeping SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014140",
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      "content": "investigation, but I specifically precluded direct evidence of failure of investigative techniques. MR. EVERDELL: I'm not saying an investigative technique per se, your Honor. I'm simply pointing out that evidence that a jury might expect to see, given we are in the modern era, is not present in front of them because of the age of the allegations. So I think this point through the agent clarifies the fact that these records don't exist anymore, they tried to get them, I think, and they didn't exist. It's not a particular technique, it's just highlighting the fact that, in a case of this age, there are records that have disappeared, phone records get deleted after a while, there is no such thing as geo location information, there weren't cellphones that had these things. So pointing it out to the agent is simply pointing out the absence of evidence because there wouldn't be anything in the record to argue that to the jury if I'm not allowed to put that in front of -- through this agent. I mean, there needs to be some explanation of the fact that I think this agent could provide that these people didn't have cellphones to their knowledge, so they wouldn't have had geo location information and that's why we don't have it in this case. MR. ROHRBACH: I'm a little confused why the defense wants to put this in, your Honor. We've had testimony in this case from a custodian and others about what recordkeeping",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00014140",
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  "entities": {
    "people": [
      "MR. EVERDELL",
      "MR. ROHRBACH"
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      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
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      "763",
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