DOJ-OGR-00018881.pdf

Case 1:20-cr-00330-PAE Document 755 Filed 08/10/22 Page 19 of 262 1724 LC8Cmax1 THE COURT: That may or may not be true depending on the testimony. MS. STERNHEIM: Well, it would be hearsay as to her knowledge, having gained it from somebody remotely in the company providing that to her. THE COURT: So if her testimony is, this is the practice and this was the longstanding practice, I learned it from predecessors or the like, she might have -- just as her understanding of the practice of maintaining records is what she learned in the course of her employment, it may be -- I'm doubtful that we'll get this testimony. We'll see what the testimony is. My current thinking is 823 comes in. That gives -- I mean, what I understand the relevance to be -- and there is no objection to 823. 824, absent the content, I'm not sure gets you anything beyond what 823 gets you. MR. ROHRBACH: I think that's right, your Honor. If 824 could not come in with the content, we probably would not offer 824. I would like to just have this conversation with Ms. Gill, as she's been the head of HR for Mar-a-Lago for quite a long time. She's reviewed this particular employment file, which is much larger than this set of records. So I think she may have a great well more to say about these issues and we would like to be able to talk with her. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018881