DOJ-OGR-00018878.pdf

Case 1:20-cr-00330-PAE Document 755 Filed 08/10/22 Page 16 of 262 1721 LC8Cmax1 that's a document created by managers at Mar-a-Lago and not the employee. THE COURT: I think, probably, 823 comes in, depending on the business record foundation, which essentially provides -- right. So this is a personnel form of Mar-a-Lago that your witness will testify they maintained in their records of employees? MR. ROHRBACH: Yes, your Honor. THE COURT: So that, I think, you're right. Ms. Sternheim, do you have an objection to 823? MS. STERNHEIM: No. THE COURT: 824, I think that Ms. Sternheim is right, that the information filled out by the employee, which you're seeking to assert for the truth, essentially that Virginia Roberts was his daughter, as I understand it. MR. ROHRBACH: Yes, your Honor. THE COURT: It would be hearsay unless there is testimony -- under the Lieberman case, unless there is testimony that the employer does something to verify the information. MR. ROHRBACH: I've never asked that question of Ms. Gill, your Honor. I'm happy to do so while we're waiting for the remaining juror. I would imagine she would say that Mar-a-Lago provides benefits to the daughter as a dependent of Mr. Roberts. So in the sense that they are, in fact, providing SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018878