DOJ-OGR-00018527.pdf

--- Page 1 --- **Document Extraction** **Case Information:** * Case Number: 1:20-cr-00330-PAE * Document Number: 751 * Filed Date: 08/10/22 **Page Information:** * Page Number: 190 of 261 * Page Size: 1351 **Text Extraction:** ( Jury not present) THE COURT: Counsel, matters to take up before the break? MS. MOE: Not from the government, your Honor. Thank you. MR. EVERDELL: Your Honor, defense has one matter. The next witness I believe is Kelly Maguire, who is going to go and introduce the exhibits, the 900 series exhibits among other things that we've already discussed. There are two photographs in there, and we did discuss these, so I wasn't -- did not get a chance to preview this for the government yet, but there are two photographs, I believe it's 919 and 920, that show the outfits, the schoolgirl outfits. Now, the Court ruled before that those wouldn't be put before the jury unless witness 3, or Kate, was able to link them up. She did talk about wearing a schoolgirl outfit. However, she was not shown those photographs in her direct. So I think we have a similar problem to what we had with Kate -- sorry. With Jane where she described a schoolgirl outfit, but she didn't look at the actual photos that they want to introduce and say those look like the schoolgirl outfits I was wearing on the day I described. So, at this point, because I don't think there is a proper foundation for the same reasons as we had with Jane, I would object to those photos being admitted. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018527