DOJ-OGR-00018664.pdf

Case 1:20-cr-00330-PAE Document 753 Filed 08/10/22 Page 66 of 264 1492 LC7Cmax2 Flatley - direct 1 A. Created on September 7th, 2002. 2 Q. And what is listed as the date last saved? 3 A. September 13th, 2002. 4 Q. What is listed here for last printed? 5 A. September 7th, 2002. 6 Q. And what is listed as the total editing time? 7 A. 30 minutes. 8 Q. Mr. Flatley, just focusing on -- 9 THE COURT: I'm sorry, Ms. Pomerantz. I can't hear you. 10 MS. POMERANTZ: I'm sorry, your Honor. My apologies. 11 Q. Looking at Government Exhibit 420, what is the date in the top-right corner? 12 A. September 7th, 2002. 13 Q. And if you could read the title of the document, please. 14 A. Sure. It's PB New Shampoo and Massage Products. 15 MS. POMERANTZ: Ms. Drescher, we can take that down. 16 Thanks very much. 17 Ms. Drescher, could you now publish Government Exhibit 418R and 418B. They're already in evidence, so we can publish them side by side, please. 18 Q. Let's start with 418R, Mr. Flatley. On the first page, can you read the top of the document, which I'm going to ask Ms. Drescher to highlight for you. 19 A. It says, Palm Beach House Workers. 20 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018664