EFTA00031257.pdf

Type: pdf
Source set: data-set-8
Extracted text

From:  
 
 
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To:  
 
 
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Subject: RE: Paul Kane Q&A 
Date: Mon, 29 Nov 2021 06:06:27 +0000 
Attachments: Kane_Q&A_v2.docx 
Hey 
I know you have a million other things going on, but I thought you might want to glance over the Paul Kane Q&A again at 
some point, since he's going after Besselsen, who's going after Matt. 
Thanks! 
From: 
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> 
Sent: Sunday, November 14, 2021 12:54 PM 
To: 
Subject: RE: Paul Kane Q&A 
Great—two main comments: 
1. A lot of questions about record keeping practices are about present practices, but I would guess things may have 
been different in 1997, so you'll want to navigate that in your meeting with him and adjust the questions 
accordingly. 
2. The closing questions (after the record is in evidence) ask the witness to read out loud on the open record the 
identifying information for MV1, so you'll need to adjust those. 
From: 
Sent: Sunday, November 14, 2021 1:31 AM 
To: 
Subject: Paul Kane Q&A 
He' 
Attached is a draft Paul Kane Q&A. There are a couple questions that may seem weird — basically, since PCS didn't create 
this record, the questions are aimed at a line of Second Circuit cases holding that "Records maintained but not created by 
a company may be admissible as business records of that company if witnesses testify that the records are integrated into 
[the] company's records and relied upon in its day-to-day operations." United States v. Kuthuru, 665 F. App'x 34, 39 (2d Cir. 
2016). 
Let's chat about the other hearsay issue when you have a minute? 
Assistant United States Attorney 
Southern District of New York 
1 Saint Andrews Plaza 
New York, New York 10007 
EFTA00031257


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