DOJ-OGR-00010163.jpg

484 KB

Extraction Summary

2
People
4
Organizations
1
Locations
1
Events
1
Relationships
2
Quotes

Document Information

Type: Legal document
File Size: 484 KB
Summary

This document is a page from a court transcript filed on March 22, 2022. In it, an attorney argues to a judge that an opposing counsel's failure to investigate a matter was not a strategic choice to "sandbag" the court, but rather a result of incompetence, described as being "careless" and "inept." The speaker references a standard from the Second Circuit and the judge's own prior findings to argue that the other counsel "dropped the ball."

People (2)

Name Role Context
Nardello
Mentioned as part of the "Nardello firm," which could have been hired to investigate.
Your Honor Judge
The person being addressed by the speaker in the court proceeding.

Organizations (4)

Name Type Context
Nardello firm Firm (likely investigative or legal)
Mentioned as a firm that could have been "unleashed" to investigate more.
The Court Government agency (judiciary)
Referenced throughout as the entity being addressed, the entity that could be "unleashed," and the author of an opinion.
Second Circuit Government agency (U.S. Court of Appeals)
Referenced for its terminology regarding legal oversight: "to use the Second Circuit's word, it was an oversight, it ...
SOUTHERN DISTRICT REPORTERS, P.C. Company
Listed at the bottom of the page as the court reporting service that transcribed the proceeding.

Timeline (1 events)

2022-03-22
An attorney makes an argument to a judge regarding another counsel's failure to conduct a proper investigation into a woman described as "crazy."
Courtroom
Unidentified speaker (counsel) Judge ("your Honor")

Locations (1)

Location Context
Appears in the name of the court reporting company, "SOUTHERN DISTRICT REPORTERS, P.C."

Relationships (1)

Unidentified speaker Professional Judge ("your Honor")
The speaker formally addresses the judge as "your Honor" while presenting a legal argument in a courtroom setting.

Key Quotes (2)

"they were playing a strategic game that they were out to sandbag a court or they were out to get an acquittal. They didn't do it because, to use the Second Circuit's word, it was an oversight, it was careless, it was inept."
Source
— Unidentified speaker (Arguing that another counsel's failure to investigate was due to incompetence rather than a deliberate strategy.)
DOJ-OGR-00010163.jpg
Quote #1
"I think your Honor's findings are that these people really dropped the ball, and they failed to do what they"
Source
— Unidentified speaker (Summarizing the speaker's interpretation of the judge's own findings to support their argument.)
DOJ-OGR-00010163.jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (1,723 characters)

Case 2:20-cr-00333-DAB-Nm Document 1643-20 Filed 03/22/22 Page 656 of 1717
A-5908
6
CAC3PARC
1 themselves we could just tell the judge.
2 Strickland talks about counsel has a duty to make
3 reasonable investigations or make a reasonable decision that
4 makes particular investigation unnecessary. And if ever there
5 was a reason either to investigate more, to unleash the
6 Nardello firm, or, I say this respectfully, unleash the Court.
7 Because as crazy as this woman was, I've always thought if your
8 Honor brought her out and said are you the same person, I'm not
9 sure her lying would have gone that far. You may disagree with
10 me on that, but I think she would have had trouble here.
11 But nobody does it. And nobody does it not because
12 they were playing a strategic game that they were out to
13 sandbag a court or they were out to get an acquittal. They
14 didn't do it because, to use the Second Circuit's word, it was
15 an oversight, it was careless, it was inept. And if I'm right
16 about that, then I think one has met the first prong here, and
17 then the question becomes prejudice.
18 And I can talk more, your Honor, the government
19 doesn't argue sandbagging. I can talk more about why I think
20 this wasn't -- look, I've read the Court's opinion, I think
21 only seven times. And I know that the Court at the end of it
22 talks about gambling. But I don't think the Court is making
23 findings in that opinion that there was a great strategy going
24 on in that court. I think your Honor's findings are that these
25 people really dropped the ball, and they failed to do what they
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010163

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