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testified that he was the primary author of that and that it
had -- and of course it had the trustworthiness, your Honor.
So we were very careful, because we knew how important this document was, to walk him through that when we had him at his deposition. And again, your Honor, those deposition designations are set forth for next Wednesday.
THE COURT: How do we know that this is the total
record? Or is it the total record? We don't know.
MS. McCAWLEY: Well, Recarey testified we showed
him this document as an exhibit in his deposition, and he
testified regarding this being something that he recorded in
the course of his own work.
THE COURT: But it's part of the record. Is it all of
the record?
MS. McCAWLEY: Meaning all of the record of the entire
investigation? We have produced that in discovery, your Honor,
through the -- we have a FOIA response, which is how we got the
videotapes of them walking through the Palm Beach house, all of the other materials related to the investigation.
THE. COURT: I see. Okay.
MS. McCAWLEY: So then, your Honor, we deposed th
detective to try, of course, to establish that this was the record to get into evidence. Your Honor, they also mentioned -- and this is
actually in the in toto motion, but they jumped to it so I need
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
HOUSE_OVERSIGHT_011428