DOJ-OGR-00018778.jpg

475 KB

Extraction Summary

4
People
3
Organizations
1
Locations
3
Events
2
Relationships
4
Quotes

Document Information

Type: Court transcript / cross-examination
File Size: 475 KB
Summary

This document is a page from a court transcript (Case 1:20-cr-00330-PAE) dated August 10, 2022, featuring the cross-examination of a witness named Carolyn. The questioning, led by Mr. Pagliuca, focuses on the timeline of the witness's interactions with the FBI in 2007 and her subsequent filing of two civil complaints in 2008 with the assistance of her lawyer, Richard Willits. The document ends with the attorney directing the witness to a specific prior deposition for review.

People (4)

Name Role Context
Carolyn Witness
Subject of cross-examination regarding past lawsuits and FBI interactions.
Richard Willits Lawyer
Witness's lawyer in 2008.
Mr. Pagliuca Attorney
Examining attorney conducting the questioning.
The Court Judge/Presiding Officer
Acknowledges the request to display evidence.

Organizations (3)

Name Type Context
FBI
Federal Bureau of Investigation, met with the witness in 2007.
Southern District Reporters, P.C.
Court reporting agency.
DOJ-OGR
Department of Justice (implied by Bates stamp).

Timeline (3 events)

2007
Witness discussion/meeting with the FBI.
Unknown
2008
Filing of two civil complaints.
Unknown
August 10, 2022
Court filing date of this transcript document.
Court

Locations (1)

Location Context
Implied jurisdiction based on 'Southern District Reporters' and case number format.

Relationships (2)

Carolyn Attorney-Client Richard Willits
Testimony confirms she had a lawyer in 2008 named Richard Willits.
Carolyn Witness/Investigator FBI
Testimony confirms meeting with the FBI in 2007.

Key Quotes (4)

"The lawsuits that were filed in 2008 were after your first discussion with the FBI in 2007; correct?"
Source
DOJ-OGR-00018778.jpg
Quote #1
"And based on those meetings, you filed not one, but two civil complaints."
Source
DOJ-OGR-00018778.jpg
Quote #2
"I want to talk about the second civil complaint first."
Source
DOJ-OGR-00018778.jpg
Quote #3
"I don't recall."
Source
DOJ-OGR-00018778.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,144 characters)

Case 1:20-cr-00330-PAE Document 753 Filed 08/10/22 Page 180 of 264 1618
LC7Cmax6 Carolyn - cross
1 A. Yes.
2 Q. And you also had a lawyer in 2008 named Richard Willits.
3 Do you remember Mr. Willits?
4 A. Yes, I do.
5 Q. The lawsuits that were filed in 2008 were after your first
6 discussion with the FBI in 2007; correct?
7 A. I'm not sure.
8 Q. Well, you met with the FBI in 2007 and then there was a
9 lawsuit in 2008; right?
10 A. Correct.
11 Q. And before the lawsuits were filed, you had lawyers; right?
12 A. Correct.
13 Q. And you had meetings with lawyers about the lawsuits?
14 A. Yes.
15 Q. And based on those meetings, you filed not one, but two
16 civil complaints. Do you recall that?
17 A. I -- yeah.
18 Q. I want to talk about the second civil complaint first.
19 First, you read that complaint before it was filed.
20 Do you recall that?
21 A. I don't recall.
22 MR. PAGLIUCA: If we can direct the witness to
23 3505-043, page 41, deposition page 157, lines 18 through 25.
24 If we can blow that up for the witness and the Court, please.
25 THE COURT: Okay.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00018778

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