YOUR HONOR, THESE ARE THE ORIGINALS OF THE NOTES THAT COUNSEL HAD SUBMITTED TO A QUESTIONED DOCUMENT EXAMINER AND THIS WAS FOR SOME SORT OF ANALYSIS ON -- I THINK MAYBE IT WAS A TRACE ANALYSIS. I DON'T KNOW EXACTLY WHAT IT WAS AND WHAT THE PURPOSE OF DOING IT WAS. BUT IF IN FACT THEY ARE GOING TO OFFER THAT INTO EVIDENCE, THEN THE PROSECUTION MIGHT NEED TO ACTUALLY LOOK AT THESE ITEMS AND DO THE SAME KIND OF ANALYSIS. SO AT THIS POINT, I DON'T SEE ANY REASON TO INTRODUCE THE ORIGINAL AS OPPOSED TO A XEROX COPY.
WELL, I THINK THAT JUST AS WE'VE DONE ALREADY, IF THE PROSECUTION WANTS TO ANALYZE THAT, THEY CAN GET AN ORDER FROM THE COURT, THE DOCUMENT CAN BE TAKEN FROM THE COURT AND GIVEN TO THEIR DOCUMENT EXAMINER. MR. GOLDMAN WENT OVER THESE DOCUMENTS IN GREAT DETAIL WHEN I DID OR WHAT WAS EXAMINED WHEN IT WAS EXAMINED.
WELL, WE'VE ALSO BEEN TOLD BY THE SCIENTIFIC INVESTIGATION EVIDENCE PEOPLE THEY WANT TO KEEP A COMPLETE SET OF THEIR DOCUMENTS. IF WE START TAKING IT APART AND INTRODUCING TWO PAGES THERE AND THREE PAGES THERE, THEN OUR ONLY SET OF THE ORIGINALS IS GONE.
KEY QUOTEWELL, THIS PARTICULAR PURPOSE -- MY ONLY PURPOSE IN SHOWING THIS DOCUMENT AT THIS TIME TO THE WITNESS IS THAT -- IS TO IMPEACH HIM WITH THE FACT THAT THE ORIGINAL DOES NOT HAVE ANY NOTATIONS AS TO WHO COLLECTED THE EVIDENCE AND HE HAS NOW RECONSTRUCTED ANOTHER SET OF NOTES FROM SOME -- IN SOME FASHION THAT I'M GOING TO EXPLORE.
I'LL ALLOW YOU TO USE THE ORIGINAL FOR THIS PURPOSE, BUT WHAT WILL GO INTO EVIDENCE WILL BE A PHOTOCOPY OF THAT.
KEY QUOTECAN I MAKE THIS REQUEST OF THE COURT THEN? I WOULD -- I HAVE NO PROBLEM WHATSOEVER WITH THE ENTIRE VOLUME OF ORIGINAL EXHIBITS BEING HELD BY THE COURT SO THAT NOBODY CAN GET TO IT IF THAT'S THEIR PROBLEM OR FEAR, AND IF THEY WANT TO DO ANY SUBSEQUENT DOCUMENT EXAMINING, TESTING, THEY CAN.
NO. BUT I THINK THE PUBLIC ENTITY IS ENTITLED TO KEEP THEIR ORIGINAL DOCUMENT IF A PHOTOCOPY WILL SUFFICE FOR THIS PURPOSE. FOR THE PURPOSE YOU TOLD ME, A PHOTOCOPY WILL SUFFICE. ALL RIGHT. LET'S GO.
MY ONLY PURPOSE IN SHOWING THIS DOCUMENT AT THIS TIME TO THE WITNESS IS THAT -- IS TO IMPEACH HIM WITH THE FACT THAT THE ORIGINAL DOES NOT HAVE ANY NOTATIONS AS TO WHO COLLECTED THE EVIDENCE AND HE HAS NOW RECONSTRUCTED ANOTHER SET OF NOTES FROM SOME -- IN SOME FASHION THAT I'M GOING TO EXPLORE.
I'LL ALLOW YOU TO USE THE ORIGINAL FOR THIS PURPOSE, BUT WHAT WILL GO INTO EVIDENCE WILL BE A PHOTOCOPY OF THAT.
WE'VE ALSO BEEN TOLD BY THE SCIENTIFIC INVESTIGATION EVIDENCE PEOPLE THEY WANT TO KEEP A COMPLETE SET OF THEIR DOCUMENTS. IF WE START TAKING IT APART AND INTRODUCING TWO PAGES THERE AND THREE PAGES THERE, THEN OUR ONLY SET OF THE ORIGINALS IS GONE.