testified that he was the primary author of that and that it

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 125 H3vlgiu2 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