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been prepared by the state's attorney's office but he didn't

know. So what happens then with this transcript is, there is

an attempt at a deposition of Ms. Hall in Miami, this summer,

and Ms. Hall comes in and she sits down, and she doesn't want

to answer any questions about anything, and she says, I don't remember anything about any of this. Her lawyer says, she

doesn't remember anything about any of this and she spent the

last ten years forgetting about all of this and she's not going

to remember anything about this. Mr. Edwards then puts the

transcript in front of her and she doesn't look at it. She

doesn't even look at the transcript. She doesn't turn the

page. She doesn't read any of it. There's a question asked at

some point later: Isn't it true that everything you said in

the police department was true? And then shortly after that,

the deposition ends. And they're trying to say that that is a sufficient factual basis and an evidentiary basis for the admission of this transcript, which is, you know, unsponsored hearsay.

There's a similar problem with this recording because

Ms. Hall never listened to the recording, never authenticated

the recording. And so there's no evidence whatsoever that it's

Ms. Hall's statement or that it was subject to any

cross-examination.

So to try to get around all of these evidentiary

problems, now what's being advanced by the plaintiffs is, well,

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

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