DOJ-OGR-00017617.jpg
569 KB
Extraction Summary
4
People
2
Organizations
2
Locations
1
Events
2
Relationships
4
Quotes
Document Information
Type:
Court transcript (case 1:20-cr-00330-pae)
File Size:
569 KB
Summary
This document is a page from a court transcript (Case 1:20-cr-00330-PAE, likely US v. Ghislaine Maxwell) filed on August 10, 2022. Defense attorney Mr. Everdell argues to the Judge that a photograph of a witness's house was not disclosed earlier because it was intended solely as impeachment material to contradict the witness's testimony, rather than evidence for the case-in-chief. The Judge and Mr. Everdell discuss Rule 16 discovery obligations, with the Judge noting that prosecutor Mr. Rohrbach likely agrees with the procedural distinction.
People (4)
| Name | Role | Context |
|---|---|---|
| Mr. Everdell | Defense Attorney |
Arguing regarding the admissibility and disclosure of impeachment material (photograph) against a witness.
|
| The Court | Judge |
Presiding over the discussion regarding evidence rules and discovery.
|
| Mr. Rohrbach | Prosecutor (Government) |
Mentioned by the Judge as agreeing with the procedural point.
|
| Unnamed Witness ('She') | Witness |
The subject of the impeachment material; her recollection of 'her house' is being challenged.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Southern District Reporters, P.C. | ||
| DOJ |
Source of the document (DOJ-OGR footer).
|
Timeline (1 events)
Locations (2)
| Location | Context |
|---|---|
|
Jurisdiction of the court (likely SDNY).
|
|
|
Subject of a photograph used for impeachment.
|
Relationships (2)
Dialogue regarding legal procedure and agreement on specific points.
Mentioned in context of agreement on legal standards between defense and prosecution.
Key Quotes (4)
"That is pure impeachment material."Source
DOJ-OGR-00017617.jpg
Quote #1
"Up to the point where you said it contradicted what she said on the stand, you and I were in vigorous agreement."Source
DOJ-OGR-00017617.jpg
Quote #2
"So that's why we did not disclose it ahead of time, because we believed it to be impeachment material."Source
DOJ-OGR-00017617.jpg
Quote #3
"I think, Mr. Rohrbach agrees."Source
DOJ-OGR-00017617.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,428 characters)
Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 8 of 264 414
LC1VMAX1
LC1VMAX1
1 use it, to show that she doesn't have an accurate recollection.
2 That is pure impeachment material.
3 THE COURT: Up to the point where you said it
4 contradicted what she said on the stand, you and I were in
5 vigorous agreement.
6 MR. EVERDELL: Okay.
7 THE COURT: Okay.
8 MR. EVERDELL: All right.
9 Well, what I would say is that we can't -- no, this is
10 not -- it's not as if we were going to introduce the photograph
11 of her house in our case-in-chief. We are doing this -- we had
12 it ready to be able to use it in case she said something that
13 we believe was contradictory and contradicted by the
14 photograph. So that's why we did not disclose it ahead of
15 time, because we believed it to be impeachment material.
16 By the way, Judge, I'll just note for the record that
17 when we sent our Rule 16 discovery several weeks ago to the
18 government, we included a cover letter, which I'm happy to
19 share with the Court --
20 THE COURT: I can imagine it reserved all your rights.
21 And you can keep talking, but we remain in agreement.
22 MR. EVERDELL: Okay. And it cited all the cases that
23 we cited, and it said we do not consider impeachment material
24 or refreshing material case-in-chief material.
25 THE COURT: It is true. I think, Mr. Rohrbach agrees.
2 That is pure impeachment material.
3 THE COURT: Up to the point where you said it
4 contradicted what she said on the stand, you and I were in
5 vigorous agreement.
6 MR. EVERDELL: Okay.
7 THE COURT: Okay.
8 MR. EVERDELL: All right.
9 Well, what I would say is that we can't -- no, this is
10 not -- it's not as if we were going to introduce the photograph
11 of her house in our case-in-chief. We are doing this -- we had
12 it ready to be able to use it in case she said something that
13 we believe was contradictory and contradicted by the
14 photograph. So that's why we did not disclose it ahead of
15 time, because we believed it to be impeachment material.
16 By the way, Judge, I'll just note for the record that
17 when we sent our Rule 16 discovery several weeks ago to the
18 government, we included a cover letter, which I'm happy to
19 share with the Court --
20 THE COURT: I can imagine it reserved all your rights.
21 And you can keep talking, but we remain in agreement.
22 MR. EVERDELL: Okay. And it cited all the cases that
23 we cited, and it said we do not consider impeachment material
24 or refreshing material case-in-chief material.
25 THE COURT: It is true. I think, Mr. Rohrbach agrees.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
(212) 805-0300
DOJ-OGR-00017617
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