DOJ-OGR-00008379.jpg
687 KB
Extraction Summary
3
People
1
Organizations
0
Locations
2
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
687 KB
Summary
This legal document, part of a court filing, argues against the defendant's proposal to call Brad Edwards, counsel for a witness named Kate, to testify. The filing asserts that Edwards' testimony about providing a U-Visa application for Kate is irrelevant for impeachment because it is consistent with Kate's own testimony and does not constitute 'powerful evidence of motive of bias' as the defense claims.
People (3)
| Name | Role | Context |
|---|---|---|
| Brad Edwards | counsel for Kate |
The defendant proposes to call him to testify that he provided a U-Visa application to the Government on behalf of Kate.
|
| Kate | Witness |
A witness who testified about asking the Government for a U-Visa. Brad Edwards is her counsel.
|
| Scarola |
Mentioned in the context of "Scarola’s proposed testimony" as a comparison point.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
Mentioned throughout as the entity Kate and her counsel, Brad Edwards, interacted with regarding a U-Visa application.
|
Timeline (2 events)
A meeting where Kate asked the Government to look into sponsoring her for a U-Visa. Brad Edwards likely attended.
Relationships (2)
The document explicitly states that Brad Edwards is 'counsel for Kate'.
Kate testified and had a meeting with the Government to inquire about a U-Visa.
Key Quotes (2)
"powerful evidence of motive of bias"Source
— the defendant
(A quote from the defendant's letter describing the significance of the U-Visa form provided by Kate's lawyer.)
DOJ-OGR-00008379.jpg
Quote #1
"powerful"Source
— the defendant
(Used to describe the evidence, which the author of this document disputes.)
DOJ-OGR-00008379.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,006 characters)
Case 1:20-cr-00330-PAE Document 545 Filed 12/15/21 Page 6 of 9
B. Brad Edwards
The defendant proposes to call Brad Edwards, counsel for Kate, to say that he provided a U-Visa application to the Government on behalf of Kate. This testimony, too, would not be privileged, but it is irrelevant and improper impeachment.
Kate testified that, at a meeting, she asked the Government to look into sponsoring her for a U-Visa. (Tr. 1279, 1287, 1300). She acknowledged that Edwards likely attended the meeting, but did not recall whether he provided a U-Visa form to the Government (Tr. 1300). Kate also explained that her plan is simply to renew her current visa, and that the Government has made no promises to assist her. (Tr. 1207-08, 1295).
The fact that Edwards provided the Government with a U-Visa application form during a meeting with Kate is not relevant or impeaching of Kate. Rather, it is entirely consistent with Kate’s testimony—specifically, that she made an inquiry about a U-Visa but was not sure whether her lawyer provided the Government with a U-Visa form. And the fact that her lawyer provided the Government with a U-Visa form is not “powerful evidence of motive of bias,” as the defendant suggests. (Def. Letter at 6). First, as with Scarola’s proposed testimony, it could only be evidence of Kate’s bias to the extent she is aware of the fact, a predicate which the defense did not establish. Second, it is not “powerful” evidence of anything. Kate acknowledged asking the Government about a U-Visa. Whether her lawyer, at the same time, gave the Government a partially complete U-Visa form is at most marginally confirming extrinsic evidence of Kate’s own testimony. It does not show, for instance, that Kate or Edwards continued to seek a U-Visa after the meeting, that she continues to seek one now, or that the Government has made any promises to Kate of any kind about her immigration status, nor could the defense argue any of that from the anticipated
6
DOJ-OGR-00008379
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document