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fe N Ww ws Oo OY ~] oO WO a oO a fe N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-PAE Document 757 Filed 08/10/22 Page /7 of 49 1980 LCOVMAXT As we explained to the defense this morning, we anticipate calling Special Agent Michael Buscemi as a summary witness, as is common in this district. His testimony will be limited to his analysis of exhibits; he won't be analyzing testimony of other witnesses. There are a number of exhibits in this case which have not yet been published or reviewed during the course of this case; and so we anticipate fairly brief testimony from Special Agent Buscemi about his review of several exhibits. In short, the testimony will concern, among other things, the message pads, the majority of which have not been published or viewed by the jury at this point. And the purpose of the testimony is to connect up several exhibits and review them in a way to make those exhibits clear to the jury and publish them to show, for example, the continuity of certain phone numbers and names, where they change over time, where they are in the message books in order to make that clear for the jury. anticipate that the testimony from Special Agent Buscemi would be likely something like 15 to 20 minutes, maybe slightly more, again, just talking about exhibits and the similarity of phone numbers and names between a variety of different exhibits. That's the scope of his testimony. Our view is that's consistent with the way summary witnesses are called in many trials in this district and SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00013548