DOJ-OGR-00018874.pdf

Case 1:20-cr-00330-PAE Document 755 Filed 08/10/22 Page 12 of 262 1717 LC8Cmax1 1 copies. 2 MS. STERNHEIM: Judge, the fact that somebody fills out a request for insurance does not deem it a business record. 3 It is not related to the course of business of the Mar-a-Lago property, and the government is trying, through a backdoor method, to draw an inference that because a person named Virginia Roberts was insured by a man named Sky Roberts, that she was, one, employed by Mar-a-Lago or, two, was at Mar-a-Lago. Insurance does not support that. 4 THE COURT: Nothing in these records appears support that she was employed at Mar-a-Lago. 5 MR. ROHRBACH: The government agrees, your Honor, these records don't give rise to that. 6 THE COURT: But you're trying to show that? 7 MR. ROHRBACH: That she was the dependent of a Mar-a-Lago employee. 8 On the insurance point, I would note that Sky Roberts was not an outsider to Mar-a-Lago at the time he filled out the employee benefits forms. He was an employee of Mar-a-Lago, and one of the things Mar-a-Lago does is provide benefits to its employees. 9 THE COURT: And then on the business records, your argument, Ms. Sternheim, is that because it's a form filled out by Mar-a-Lago employees for the purposes of insurance that's provided by another entity, that they're not a Mar-a-Lago SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018874