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Case 1:20-cr-00330-AJN Document 763 Filed 08/10/22 Page 60 of 197 2601
LCHVMAX2
Q.
years ago and now,
As
Q.
no
la
Right. And you've done a lot of intervi
Probably thousands.
testify from and be con
is
Avs
Q.
statements in this JR-1 that we've marked
Richards
assume?
—- direct
ws between 14
tes and to record events accurately,
Now, is part of the reason why you are trained to take
so that months or years
ter you will have a document such as this that you can
fident that what you put in the document
accurate?
That's for reference, yes.
Okay. What I'd like to do is direct you to some specific
purposes.
First of all,
you spoke with Carolyn?
for identification
do you recall that on August 7th, 2007,
And we're
identifying this person only
by the name of "Carolyn."
A» YES.
Q. And again, when you spoke with Carolyn,
in
correct?
A. That's correct.
Q. When you spoke with Carolyn,
and experience,
as
A.
Q.
you were at
possible; is that correct?
Yes.
And you were not limiting any of
you were gathering
formation relative to your investigation at that time;
consistent with your training
Lempting to get as much information
the responses given to you
SOUTHERN
D
STR
CT RE
PORTERS,
(212)
805-
0300
PG ew
DOJ-OGR-00016789