DOJ-OGR-00009484.jpg
481 KB
Extraction Summary
2
People
5
Organizations
1
Locations
1
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
481 KB
Summary
This document is a court transcript from February 24, 2022, in which an attorney argues before a judge. The attorney contends that the opposing counsel's failure to properly investigate a witness was not a strategic tactic ('sandbagging') but rather incompetence, carelessness, and an oversight, quoting the Second Circuit's language. The speaker believes this failure to act constitutes prejudice and that the opposing side "dropped the ball."
People (2)
| Name | Role | Context |
|---|---|---|
| Nardello |
Mentioned in the context of the "Nardello firm," which could have been hired to investigate.
|
|
| your Honor | Judge |
The speaker is addressing the judge directly throughout the transcript.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| Nardello firm | company |
An entity that could have been hired to "investigate more."
|
| the Court | government agency |
Referenced multiple times as the judicial body hearing the case.
|
| the Second Circuit | government agency |
A higher court whose words ("oversight," "careless," "inept") are being quoted by the speaker.
|
| the government | government agency |
Mentioned as a party in the legal proceedings that "doesn't argue sandbagging."
|
| SOUTHERN DISTRICT REPORTERS, P.C. | company |
The court reporting agency that transcribed the proceedings.
|
Timeline (1 events)
2022-02-24
An attorney is presenting an oral argument to a judge in case 1:20-cr-00330-PAE.
Southern District Court
Unnamed counsel
Judge
Locations (1)
| Location | Context |
|---|---|
|
Identified as the location of the court reporters, likely referring to a U.S. Federal Judicial District.
|
Relationships (1)
Unnamed counsel
→
professional
→
Judge ('your Honor')
The document is a transcript of the counsel making a legal argument directly to the judge in a formal court setting.
Key Quotes (3)
"Because as crazy as this woman was, I've always thought if your Honor brought her out and said are you the same person, I'm not sure her lying would have gone that far."Source
— Unnamed counsel
(The speaker is speculating that confronting a witness in court would have exposed her dishonesty.)
DOJ-OGR-00009484.jpg
Quote #1
"They didn't do it because, to use the Second Circuit's word, it was an oversight, it was careless, it was inept."Source
— Unnamed counsel
(The speaker is characterizing the opposing counsel's failure to act as incompetence rather than a deliberate legal strategy.)
DOJ-OGR-00009484.jpg
Quote #2
"I think your Honor's findings are that these people really dropped the ball, and they failed to do what they"Source
— Unnamed counsel
(The speaker is summarizing their interpretation of the judge's view on the opposing counsel's performance.)
DOJ-OGR-00009484.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,609 characters)
Case 1:20-cr-00330-PAE Document 1616-3 Filed 02/24/22 Page 65 of 117
A-5908
A-5908
6
CAC3PARC
themselves we could just tell the judge.
Strickland talks about counsel has a duty to make
reasonable investigations or make a reasonable decision that
makes particular investigation unnecessary. And if ever there
was a reason either to investigate more, to unleash the
Nardello firm, or, I say this respectfully, unleash the Court.
Because as crazy as this woman was, I've always thought if your
Honor brought her out and said are you the same person, I'm not
sure her lying would have gone that far. You may disagree with
me on that, but I think she would have had trouble here.
But nobody does it. And nobody does it not because
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. And if I'm right
about that, then I think one has met the first prong here, and
then the question becomes prejudice.
And I can talk more, your Honor, the government
doesn't argue sandbagging. I can talk more about why I think
this wasn't -- look, I've read the Court's opinion, I think
only seven times. And I know that the Court at the end of it
talks about gambling. But, I don't think the Court is making
findings in that opinion that there was a great strategy going
on in that court. I think your Honor's findings are that these
people really dropped the ball, and they failed to do what they
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
themselves we could just tell the judge.
Strickland talks about counsel has a duty to make
reasonable investigations or make a reasonable decision that
makes particular investigation unnecessary. And if ever there
was a reason either to investigate more, to unleash the
Nardello firm, or, I say this respectfully, unleash the Court.
Because as crazy as this woman was, I've always thought if your
Honor brought her out and said are you the same person, I'm not
sure her lying would have gone that far. You may disagree with
me on that, but I think she would have had trouble here.
But nobody does it. And nobody does it not because
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. And if I'm right
about that, then I think one has met the first prong here, and
then the question becomes prejudice.
And I can talk more, your Honor, the government
doesn't argue sandbagging. I can talk more about why I think
this wasn't -- look, I've read the Court's opinion, I think
only seven times. And I know that the Court at the end of it
talks about gambling. But, I don't think the Court is making
findings in that opinion that there was a great strategy going
on in that court. I think your Honor's findings are that these
people really dropped the ball, and they failed to do what they
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009484
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