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639 KB
Extraction Summary
4
People
2
Organizations
0
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Court transcript
File Size:
639 KB
Summary
This document is a court transcript from August 10, 2022, detailing legal arguments about privileged communications. An attorney, Ms. Sternheim, argues that answers to interrogatories and a complaint are not privileged, while another attorney, Ms. Comey, begins to dispute the accuracy of a deposition. The judge rules that arguments about a witness's story changing over time due to the involvement of civil lawyers are matters to be presented to a jury.
People (4)
| Name | Role | Context |
|---|---|---|
| Ms. Sternheim | Speaker (likely an attorney) |
Identified in the header as the speaker for the 'Opening'.
|
| Mr. Scarola | Lawyer |
Mentioned as the lawyer who wrote answers to interrogatories for a client.
|
| Ms. Comey | Speaker (likely an attorney) |
Addresses the court as 'Your Honor' regarding the factual accuracy of a deposition.
|
| THE COURT | Judge |
A speaker in the transcript, responding to attorneys and making rulings on arguments.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| SOUTHERN DISTRICT REPORTERS, P.C. | Company |
Listed at the bottom of the transcript, likely the court reporting agency.
|
| victim compensation fund | Fund |
Mentioned as a source of money being sought by one of the parties.
|
Timeline (2 events)
2022-08-10
A court proceeding where attorneys Ms. Sternheim and Ms. Comey are making arguments before a judge (THE COURT).
Court
A deposition is mentioned by Ms. Comey, who disputes its factual accuracy.
Relationships (1)
The document states Mr. Scarola is the 'lawyer on this topic' who 'wrote all the answers to interrogatories and were signed by the client'.
Key Quotes (3)
"First of all, all the answers to interrogatories are not privileged. The communications in the complaint are not privileged."Source
— Ms. Sternheim
(Arguing that certain legal documents should not be considered confidential.)
DOJ-OGR-00011723.jpg
Quote #1
"Your Honor, as an initial matter, it's not factually accurate that the deposition is --"Source
— MS. COMEY
(Contesting a point about a deposition before being cut off by the court.)
DOJ-OGR-00011723.jpg
Quote #2
"Okay. So these are arguments you're going to make to the jury. It's not -- the contention is that the story has changed and what happened in between was the involvement of civil lawyers."Source
— THE COURT
(Instructing an attorney that their point is an argument to be made to a jury, not a matter of privileged testimony for the court to decide at this stage.)
DOJ-OGR-00011723.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,828 characters)
Case 1:20-cr-00330-PAE Document 741 Filed 08/10/22 Page 58 of 106 62
LBTVMAX3 Opening - Ms. Sternheim
LBTVMAX3 Opening - Ms. Sternheim
1 It is only after years and after the fund is open that
2 we then have this witness coming forward in conjunction with
3 this email that I'm talking about that we've referenced in
4 papers to the Court. So, for example, Mr. Scarola, who is the
5 lawyer on this topic, wrote all the answers to interrogatories
6 and were signed by the client. Then we fast forward, and we
7 have all this information that's being provided in 2020 which
8 is not present in 2008.
9 First of all, all the answers to interrogatories are
10 not privileged. The communications in the complaint are not
11 privileged. The lack of information about our client in that
12 complaint can be inferred that after that is when all this
13 comes up, because we are seeking money from the victim
14 compensation fund and we are using the government as part and
15 parcel of that to buttress our claim to the fund.
16 MS. COMEY: Your Honor, as an initial matter, it's not
17 factually accurate that the deposition is --
18 THE COURT: Okay. So these are arguments you're going
19 to make to the jury. It's not -- the contention is that the
20 story has changed and what happened in between was the
21 involvement of civil lawyers. I have no idea what the evidence
22 exactly will show with that, and it sounds like there are going
23 to be arguments to be made on both sides, but that's not based
24 on privileged testimony. And I have a proffer that the story
25 has changed over time and what intervened between civil
2 we then have this witness coming forward in conjunction with
3 this email that I'm talking about that we've referenced in
4 papers to the Court. So, for example, Mr. Scarola, who is the
5 lawyer on this topic, wrote all the answers to interrogatories
6 and were signed by the client. Then we fast forward, and we
7 have all this information that's being provided in 2020 which
8 is not present in 2008.
9 First of all, all the answers to interrogatories are
10 not privileged. The communications in the complaint are not
11 privileged. The lack of information about our client in that
12 complaint can be inferred that after that is when all this
13 comes up, because we are seeking money from the victim
14 compensation fund and we are using the government as part and
15 parcel of that to buttress our claim to the fund.
16 MS. COMEY: Your Honor, as an initial matter, it's not
17 factually accurate that the deposition is --
18 THE COURT: Okay. So these are arguments you're going
19 to make to the jury. It's not -- the contention is that the
20 story has changed and what happened in between was the
21 involvement of civil lawyers. I have no idea what the evidence
22 exactly will show with that, and it sounds like there are going
23 to be arguments to be made on both sides, but that's not based
24 on privileged testimony. And I have a proffer that the story
25 has changed over time and what intervened between civil
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
(212) 805-0300
DOJ-OGR-00011723
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