DOJ-OGR-00018879.pdf

Case 1:20-cr-00330-PAE Document 755 Filed 08/10/22 Page 17 of 262 1722 LC8Cmax1 insurance benefits to her, they have verified that information. THE COURT: Well, it's a bit circular. I think the question is, did they do anything to verify the information on the form. The fact that they provided -- that they sent this form and then insurance was provided based on the employee's information, that's the out-of-court statement. It's Mr. Roberts' statement on this form that you're seeking to offer for the truth. So unless there is -- you'll look at the Lieberman case. I think it's directly on point, as I said. MR. ROHRBACH: I'm happy to look at the case and also ask Ms. Gill, your Honor. My point is, I think it's more than just sending the form and then obtaining insurance for someone because their name is on the form, but it's the course of conduct of paying bills for someone who then receives medical treatment because that person is insured through Mar-a-Lago. THE COURT: Well, if she's got information on this employee with respect to that or records, I suppose that's another story. MR. ROHRBACH: I think those records do exist, but I'll just go have a conversation with Ms. Gill about this. THE COURT: Ms. Sternheim. MS. STERNHEIM: Judge, the government would be asking this witness about a practice that preceded the time period in which she was there. And the fact of the matter is, requesting SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018879