DOJ-OGR-00011296.jpg

Case 1:20-cr-00330-PAE Document 711 Filed 07/12/22 Page8of11 B. Annie Trial 3500 Quote Government Defense Testimony Material Position position 2151:2 - 16 3514-001, p. Originally Maria was Objection. A denial of 2, 2d full going to accompany Although the making the paragraph Annie to New Mexico. witness testified statement that she did not may be recall making the | impeached statement, she via extrinsic acknowledged that | evidence. the statement is FRE 613(b) contained in the 302. There is no basis for further impeachment. 2160:12 — 3514-001, p. | The chef prepared dinner | Objection. Not Indicates 2161:25 3, 2d full and all three ate together. inconsistent with another eye paragraph the witness’s witness; not testimony. Also, | collateral whether a chef and prepared dinner is | inconsistent a collateral matter. | with her direct testimony 2165:7 — 3514-001, p. | They spent a significant Objection. Not Witness 2166:6 2, last amount of time horseback | inconsistent with omitted this paragraph riding. the witness’s activity from testimony. The witness did not deny making the statement on page 2166. Also, whether the witness went horseback riding for a significant amount of time is collateral. her recitation of the weekend events, although she earlier had said it was "significant" part of her trip. DOJ-OGR-00011296