DOJ-OGR-00018913.pdf

Case 1:20-cr-00330-PAE Document 755 Filed 08/10/22 Page 51 of 262 1756 LC8VMAX2 Shawn - direct 1 (At sidebar) 2 MR. PAGLIUCA: Your Honor, this Amanda person was not 3 noticed under 404(b). We had two that were noticed. As I 4 recall, that's the Melissa and Virginia, and that's it. 5 MS. MENNINGER: Not just 404(b). 6 Your Honor ordered that the government produce to us 7 the names of any victims that they intended to discuss at 8 trial. They gave the names of six individuals; the four that 9 we normally have been talking about, Ms. Roberts, and this last 10 one. But Amanda was not one of the names that they gave. So 11 if they intended to refer to her as a victim in this trial, the 12 deadline to do that was, I think, in September. 13 MS. COMEY: Your Honor, yesterday during her 14 testimony, Carolyn said that Amanda Lazlo was someone who she 15 brought with her. I asked how old Amanda was, and she said how 16 old she was. There was no objection. 17 MS. MENNINGER: She said 18. 18 MS. COMEY: This is corroborative -- I don't believe 19 she said 18. This is corroborative testimony. And I would 20 note -- 21 THE COURT: Well, the age distinction is an important 22 question. It's entirely not corroborative in identifying a new 23 victim if the testimony yesterday was 18. 24 MS. COMEY: And, your Honor, I would want to check the 25 transcript for this. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018913