DOJ-OGR-00018531.jpg
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Case 1:20-cr-00330-PAE
LC6VMAX6
MS. MOE:
to why w
Vv
and Kate,
Yes,
Document 751
your Honor.
Filed 08/10/22
And
decided not to do that in this case,
Since this has come up now twice.
explain why we've approached this this way.
Page 194 of 261 1355
I'd be happy to speak
both
for Jane
I'd be happy to
Because we tried
to be sensitive in the way we've approached our interviews with
victims in this cas
We' do
the defense has put
memories; and so it
V
in issue th
is importan
we have not shown
the victims —-
THE
COURT:
strategic decision and an understandable one.
excuse a lack of
certainl
t that
[ ge
1a
e
t
this
quality of
in terms of
for two reasons.
One,
the victims'
corroboration that
That is absolutely a
Foundation as to relevancy.
y understand why you'd make that choice,
imagine other reasons you'd make the choice.
I don't thi
way helps determine
2019 pictures of highly movable objects,
nk -—- tell
me
if
match up with the sp
from the Court's perspectiv
It does not then
It just doesn't.
and I can
I'm wrong -- that in any
whether thes
whi
ecific testimony of the
ch may or may not
witness, are
relevant to a conspiracy that ended 15 years earlier.
MS. MOE: Yes, your Honor.
And I think our argument on that is that this is an
issue of weight and not relevanc Because the argument before
the jury from this evidence is not that these are th
schoolgirl outfits or one of the schoolgirl outfits that Kate
was asked to wear.
The point is that Kate told the jury that
SOUTH
ERN D
STR
CT RE
PORT
ERS,
(212)
80
5-0300
PG ew
DOJ-OGR-00018531