epstein-docs.github.io/results/IMAGES007/DOJ-OGR-00017615.json
2025-10-07 04:24:51 +11:00

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"page_number": "6",
"document_number": "745",
"date": "08/10/22",
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"full_text": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 6 of 264 412 LC1VMAX1\n1 temporal time split, that is to say, you don't have to put on your first witness, is not the question; it's a functional question, are you putting on evidence in your case-in-chief as opposed to impeachment testimony.\n2\n3 MR. EVERDELL: I think that's right, your Honor.\n4\n5 Let's give an example, because I think it's helpful to use examples. I'll use one from this very case.\n6\n7 It's my understanding that the government wants to introduce certain FedEx records through a FedEx document custodian. The defense also would like to introduce other FedEx records, coincidentally, through the same document custodian. So if that happens, you'd have a witness called by the government, the defense would want to introduce affirmative proof in its case through that same witness. That would be defense case-in-chief material which, by the way, we disclosed in our Rule 16 letter to the government. That's an example, I think, where the courts are talking about where you disclose things -- where you have a witness where you are trying to put on affirmative proof in the defense case through the government's witness. That is an example where we don't dispute.\n8\n9 I'll give another example. This is a hypothetical one. Larry Visoski just testified. He was shown a number of pictures of Little St. James Island where there were structures, houses on the island. And he testified to those,\n10\n11 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00017615",
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"content": "1 temporal time split, that is to say, you don't have to put on your first witness, is not the question; it's a functional question, are you putting on evidence in your case-in-chief as opposed to impeachment testimony.\n2\n3 MR. EVERDELL: I think that's right, your Honor.\n4\n5 Let's give an example, because I think it's helpful to use examples. I'll use one from this very case.\n6\n7 It's my understanding that the government wants to introduce certain FedEx records through a FedEx document custodian. The defense also would like to introduce other FedEx records, coincidentally, through the same document custodian. So if that happens, you'd have a witness called by the government, the defense would want to introduce affirmative proof in its case through that same witness. That would be defense case-in-chief material which, by the way, we disclosed in our Rule 16 letter to the government. That's an example, I think, where the courts are talking about where you disclose things -- where you have a witness where you are trying to put on affirmative proof in the defense case through the government's witness. That is an example where we don't dispute.\n8\n9 I'll give another example. This is a hypothetical one. Larry Visoski just testified. He was shown a number of pictures of Little St. James Island where there were structures, houses on the island. And he testified to those,",
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"content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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"content": "DOJ-OGR-00017615",
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"entities": {
"people": [
"MR. EVERDELL",
"Larry Visoski"
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"organizations": [
"FedEx",
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"locations": [
"Little St. James Island"
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"08/10/22"
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"745",
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