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711 KB
Extraction Summary
7
People
3
Organizations
0
Locations
3
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
711 KB
Summary
This legal document presents an argument to the Court to preclude the testimony of Jack Scarola, Brad Edwards, and Robert Glassman. The core argument is that Glassman's settlement negotiations with an entity called EVCP cannot be used to impeach a witness named Jane, because she testified she was unaware of these negotiations. Allowing this testimony would be improper impeachment and more prejudicial than probative.
People (7)
| Name | Role | Context |
|---|---|---|
| Glassman |
Mentioned throughout the document regarding his conversations with the EVCP, negotiations for a settlement, and poten...
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|
| Jane | Witness |
A witness whose testimony is central to the legal argument. The document discusses her testimony, her knowledge of se...
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| Jack Scarola |
An individual whose testimony the Court is being asked to preclude.
|
|
| Brad Edwards |
An individual whose testimony the Court is being asked to preclude.
|
|
| Robert Glassman |
An individual whose testimony the Court is being asked to preclude. This is the full name for 'Glassman' mentioned ea...
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| Jane's attorney | Attorney |
Mentioned as having asked the EVCP for more money in settlement negotiations.
|
| [prosecutor] | Prosecutor |
Recipient of an email from Glassman, as quoted in a footnote.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| EVCP | unknown |
An entity from which Glassman demanded a higher settlement and with whom Jane's attorney negotiated.
|
| Court | government agency |
The judicial body presiding over the case, which is being asked to preclude testimony.
|
| Government | government agency |
Mentioned in a footnote as having received an email from Glassman.
|
Timeline (3 events)
Relationships (3)
The document discusses the possibility of privileged conversations between Jane and Glassman and how Glassman's actions relate to Jane's testimony and knowledge.
The document mentions 'her attorney asked the EVCP for more money' and a question on cross about 'The Lion King movie through your attorney to you'.
Key Quotes (4)
"there are personal knowledge questions in issue."Source
— The Court
(The Court's explanation when the defendant raised an issue on December 1.)
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Quote #1
"do not repeat or refer to statements by Jane"Source
— The defendant
(Part of the defendant's argument that Glassman's exchanges with the Government are not privileged.)
DOJ-OGR-00008381.jpg
Quote #2
"Hey [prosecutor]. Hope you guys are staying safe. Here was her response about the lion king,"Source
— Glassman
(A statement from an email sent by Glassman, quoted in a footnote.)
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Quote #3
"The government suggested to you that perhaps you meant to say The Lion King movie through your attorney to you; correct?"Source
— defense counsel
(A question posed during cross-examination, cited as an example of the defense framing questions to call for privileged information.)
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,095 characters)
Case 1:20-cr-00330-PAE Document 545 Filed 12/15/21 Page 8 of 9
would serve no proper purpose.³
Finally, Glassman’s conversations with the EVCP do not impeach Jane’s testimony. The
defendant would call Glassman to testify that he originally demanded a higher settlement from the
EVCP. As the Court explained when the defendant raised this very issue at a break on December
1, “there are personal knowledge questions in issue.” (Tr. 489). On cross, defense counsel asked
Jane if she knew whether her attorney asked the EVCP for more money, and she said she did not
know. (Tr. 558). Today, as on December 1, evidence of Glassman’s negotiations with the EVCP
(or the defendant) go to Jane’s bias only if Jane was aware of them. Jane testified that she was not
aware of them, and the evidence the defendant would elicit from Glassman would not cure that
defect. It is therefore improper impeachment. And for Glassman, as for Scarola and Edwards, the
suggestion that the jury should infer that Jane and Glassman had certain privileged conversations
that affect Jane’s knowledge from the fact that Glassman had other exchanges with other
individuals is more prejudicial than probative. See Fed. R. Evid. 403.
defendant would call Glassman to testify that he originally demanded a higher settlement from the
EVCP. As the Court explained when the defendant raised this very issue at a break on December
1, “there are personal knowledge questions in issue.” (Tr. 489). On cross, defense counsel asked
Jane if she knew whether her attorney asked the EVCP for more money, and she said she did not
know. (Tr. 558). Today, as on December 1, evidence of Glassman’s negotiations with the EVCP
(or the defendant) go to Jane’s bias only if Jane was aware of them. Jane testified that she was not
aware of them, and the evidence the defendant would elicit from Glassman would not cure that
defect. It is therefore improper impeachment. And for Glassman, as for Scarola and Edwards, the
suggestion that the jury should infer that Jane and Glassman had certain privileged conversations
that affect Jane’s knowledge from the fact that Glassman had other exchanges with other
individuals is more prejudicial than probative. See Fed. R. Evid. 403.
III. Conclusion
For the reasons set forth above, the Court should preclude testimony from Jack Scarola,
Brad Edwards, and Robert Glassman.
Brad Edwards, and Robert Glassman.
³ The defendant also argues that Glassman’s exchanges with the Government that “do not repeat
or refer to statements by Jane” are not privileged. (Def. Letter at 8). Glassman’s statements in the
email are “Hey [prosecutor]. Hope you guys are staying safe. Here was her response about the
lion king,” which are irrelevant. And the prosecutor’s statements can only be relevant to the extent
that Jane was aware of them. But the defense has not established that fact, in part because the
defense framed its questions on cross to call for privileged information. (See, e.g., Tr. 511 (“The
government suggested to you that perhaps you meant to say The Lion King movie through your
attorney to you; correct?” (emphasis added))).
or refer to statements by Jane” are not privileged. (Def. Letter at 8). Glassman’s statements in the
email are “Hey [prosecutor]. Hope you guys are staying safe. Here was her response about the
lion king,” which are irrelevant. And the prosecutor’s statements can only be relevant to the extent
that Jane was aware of them. But the defense has not established that fact, in part because the
defense framed its questions on cross to call for privileged information. (See, e.g., Tr. 511 (“The
government suggested to you that perhaps you meant to say The Lion King movie through your
attorney to you; correct?” (emphasis added))).
8
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