DOJ-OGR-00013705.pdf

Case 1:20-cr-00330-PAE Document 759 Filed 08/10/22 Page 114 of 267 2142 LCAVMAX4 A. Farmer - cross 1 A. I did not. 2 Q. And you spoke to your mother about going to New Mexico? 3 A. That's correct. 4 Q. And when you were talking to the government about all these various conversations, you told them it was harder for you to disaggregate the discussions about those two different trips, right? 8 A. I don't recall saying that, but I -- I understand what you're saying. 10 Q. Okay. And you have very little memory of how the New Mexico trip was planned; correct? 12 A. That's correct. 13 Q. And you have very little memory because you have no journal entries from that time period, right? 15 MS. POMERANTZ: Objection. 16 THE COURT: Overruled. 17 A. I have not had a journal to help me refresh my memories of how that was planned. 19 Q. Thank you. 20 Now, you testified on direct that you believe you went in the -- to New Mexico in the spring of '96, right? 22 A. That's correct. 23 Q. And you also said you believe it was April of '96? 24 A. That's right. 25 Q. And you're going off of your memory for that? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00013705