Search results for witness statement testified
2,076 results for "witness statement testified"
Page 5 of 84
DOJ-OGR-00012074.jpg
...The issue is
testified that she doe
witness the document a
recollection, which is
that juncture,
into the record, which
TH
|
COURT: W
testified —-
(Pause)
THE
COURT: S$
Epstein directed wher
Document 745
Jane -— Cross
ar)
nk you, your Honor.
but
I'm hoping
Filed 08/10/22
this will...
DOJ-OGR-00017663.jpg
...The issue is
testified that she doe
witness the document a
recollection, which is
that juncture,
into the record, which
TH
|
COURT: W
testified —-
(Pause)
THE
COURT: S$
Epstein directed wher
Document 745
Jane -— Cross
ar)
nk you, your Honor.
but
I'm hoping
Filed 08/10/22
this will...
DOJ-OGR-00014125.jpg
...Defe
of a prior in
that, quote,
nse seeks to admit extrinsic evidence
consistent statement under 613(b), which requires
the witness is given an opportunity to explain or
deny the stat
to examine th
My c
ement and an adverse party is given an opportunity
e witness about it...
DOJ-OGR-00005431.jpg
...For individuals who are not witnesses and not hearsay declarants, however, none of those
rules apply. Instead, those non-witnesses’ “credibility is irrelevant.” United States v. McGowan,
58 F.3d 8, 15-16 (2d Cir. 1995). The Second Circuit has therefore “clearly established . . . the
principle that a statement not offered...
DOJ-OGR-00006398.jpg
...For individuals who are not witnesses and not hearsay declarants, however, none of those
rules apply. Instead, those non-witnesses’ “credibility is irrelevant.” United States v. McGowan,
58 F.3d 8, 15-16 (2d Cir. 1995). The Second Circuit has therefore “clearly established . . . the
principle that a statement not offered...
DOJ-OGR-00005866.jpg
Legal
...Moreover, the defendant’s prior statements
are of course appropriate material for cross-examination of the defendant. The Government also
consents to the defense request to redact the perjury counts from the Indictment. (Def. Mot. 6 at
6).
Finally, the defense seeks to preclude the Government’s law enforcement witnesses...
DOJ-OGR-00006791.jpg
Legal
...Moreover, the defendant’s prior statements
are of course appropriate material for cross-examination of the defendant. The Government also
consents to the defense request to redact the perjury counts from the Indictment. (Def. Mot. 6 at
6).
Finally, the defense seeks to preclude the Government’s law enforcement witnesses...
DOJ-OGR-00005558.jpg
Court Filing
Case 1:20-cr-00330-PAE Document 383 Filed 10/29/21 Page4of40
PRELIMINARY STATEMENT
The Government respectfully submits this memorandum of law in further support of its
October 18, 2021 motions in limine.
ARGUMENT
I. The Court Should Permit Certain Witnesses to Testify Under Pseudonyms or
Using First Names...
DOJ-OGR-00006520.jpg
Court Filing
Case 1:20-cr-00330-PAE Document 440 Filed 11/12/21 Page4of40
PRELIMINARY STATEMENT
The Government respectfully submits this memorandum of law in further support of its
October 18, 2021 motions in limine.
ARGUMENT
I. The Court Should Permit Certain Witnesses to Testify Under Pseudonyms or
Using First Names...
DOJ-OGR-00013015.jpg
...That they had spoken with witness
11 Brian, who was anticipated to testify today. Brian is the
12 brother of witness Jane.
13 THE COURT: Correct.
14 MS. MENNINGER: You may recall, your Honor, we had
15 litigation around prior consistent statements; and that Brian
16 is being offered in...
DOJ-OGR-00018600.jpg
...That they had spoken with witness
11 Brian, who was anticipated to testify today. Brian is the
12 brother of witness Jane.
13 THE COURT: Correct.
14 MS. MENNINGER: You may recall, your Honor, we had
15 litigation around prior consistent statements; and that Brian
16 is being offered in...
DocumentCloud_Epstein_Docs_p00829.png
Court Filing
...to the statements Ms. Giuffre made about Defendant. To the contrary,
voluminous evidence, both documentary and testimonial from numerous witnesses, corroborate
Ms. Giuffre’s account of Defendant’s involvement in the sexual abuse and trafficking of Ms.
Giuffre. Just to briefly highlight a few, Johanna Sjoberg, testified that Defendant recruited...
HOUSE_OVERSIGHT_011429.jpg
...the witnesses in here, AH,
who was a minor at the time, also gave a recorded statement as
part of that. We took her deposition, and they're, you know,
in my view, vastly misrepresenting the deposition. And you can
look at the quotes themselves, but she testified in great...
DOJ-OGR-00012878.jpg
...8 Again, I think her testimony would be described as she
9 recalled it well enough to testify fully and accurately becaus
10 it doesn't conflict with what's in here. So it's not the same
11 analysis as prior inconsistent statement, but I think the
12 initial...
DOJ-OGR-00018464.jpg
...8 Again, I think her testimony would be described as she
9 recalled it well enough to testify fully and accurately becaus
10 it doesn't conflict with what's in here. So it's not the same
11 analysis as prior inconsistent statement, but I think the
12 initial...
DOJ-OGR-00008410.jpg
...The det
motives or biases
witnesses' motives
Epstein's dea
cross-examina
background in
Filed 12/17/21
Page 16 of 24 28
attack on the
line of
for testifying,
videnc
tigation t
Provided t
hat the Fifth
hat the rules
for admitting prior inconsistent statements are satisfied, the
is...
DOJ-OGR-00008519.jpg
...This is not to suggest that any witness who has an
interest in the outcome of a case would testify falsely. It is for you to decide to what extent, if at
all, the witness’s interest has affected or colored his or her testimony.
You are not required to...
Giuffre_Maxwell_Batch4_p00030.png
...Was it your impression at the time that
those statements could incriminate her?
MR. PAGLIUCA: Object to form and
foundation.
THE WITN
BY MS. SCHULTZ:
Q. You testified earlier that you interviewed
approximately 30 or 33 girls, correct?
THE WITNESS: Yes.
MR. PAGLIUCA: Object to form and
foundation.
BY MS...
Giuffre_Maxwell_Batch6_p00163.png
Legal
...First, Defendant argues that Jeffrey Epstein is not an unavailable witness and should
appear as a live witness. Ms. Giuffre would like to have him appear at trial and it appears that
Epstein’s counsel is willing to accept a subpoena for him. If so, the issue is moot. But...
DOJ-OGR-00014157.jpg
...Who's the first witness?
MR. PAGLIUCA: Jason Richards, your Honor, Special
Agent Richards, which is a short witness.
MS. COMEY: That's another witness we offered to
stipulate to, your Honor. Prior inconsistent statements,
think there are two that he's going to be called to testify --
THE COURT...
DOJ-OGR-00016780.jpg
...Who's the first witness?
MR. PAGLIUCA: Jason Richards, your Honor, Special
Agent Richards, which is a short witness.
MS. COMEY: That's another witness we offered to
stipulate to, your Honor. Prior inconsistent statements,
think there are two that he's going to be called to testify --
THE COURT...
DOJ-OGR-00013823.jpg
...Your Honor, once the government
elicits co-conspirator statements under 801(d) (2) (E), under
806, I'm allowed to impeach the declarant as though they were
testifying. So I'm asking questions about Jeffrey Epstein
through this witness, who is the one from whom they elicited
the 801(d...
DOJ-OGR-00016448.jpg
...Your Honor, once the government
elicits co-conspirator statements under 801(d) (2) (E), under
806, I'm allowed to impeach the declarant as though they were
testifying. So I'm asking questions about Jeffrey Epstein
through this witness, who is the one from whom they elicited
the 801(d...
Giuffre_Maxwell_Batch6_p00137.png
...By the way, just so -- is
what I just said correct?
THE WITNESS: Absolutely, yes. Thank you.
BY MR. EDWARDS:
Os When you gave the statement to the police,
was your motivation to tell the truth?
A. Yes.
MR. PAGLIUCA: Object to the form and
foundation.
THE WITNESS: Yes, it...
EFTA00617178.pdf
Court Filing
...803(24) inapplicable absent showing
that proponent made reasonable efforts to produce witness with direct, personal knowledge);
United States v.=
792 F.2d 1019, 1027 (11th Cir. 1986) (error in the trial court's admission
of hearsay evidence when the declarant could have been questioned about her own statements);
As...
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