DOJ-OGR-00014064.pdf

--- Page 1 --- **Document Extraction** **Case Information** * Case Number: 1:20-cr-00330-PAE * Document Number: 761 * Filed Date: 08/10/22 * Page Number: 205 of 246 **Header** * (Jury not present) **Transcript** * THE COURT: Okay. Mr. Everdell. * MR. EVERDELL: Your Honor, the exhibit is marked for identification as MA1, and I'll hand up a paper copy to the Court, and I believe the government has a copy, but I have another one for them, as well. * THE COURT: Okay. I'll hear the objection. * MS. POMERANTZ: Thank you, your Honor. Just briefly, the question posed to the defense is what is the relevance of these records, and in particular, we're talking about victim travel records that go over 15 years of victim travel records that extend well beyond the period charged in the indictment. * And so, we would ask for a proffer of relevance for the admissibility of such extensive travel information, private information of the victims. * THE COURT: So no objection within the charged timeframe? * MS. POMERANTZ: No objection. * MR. EVERDELL: Your Honor, for example, these records go up to 2010, which was the cutoff point for the request when we issued the subpoena, we, in fact, negotiated with the government over how broad the subpoena would be and we agreed that it would go to 2010. * Now, as to the relevance -- and that's why the records go that far. **Footer** * SOUTHERN DISTRICT REPORTERS, P.C. * (212) 805-0300 * DOJ-OGR-00014064 **Note**: The image appears to be a scanned document of a court transcript, with the text extracted exactly as it appears on the page.