Case 1:20-cr-00330-PAE Document 761 Filed 08/10/22 Page 205 of 246 2500 LCGCmax6 Aznaran -— direct 1 (Jury not present) 2 THE COURT: Okay. Mr. Everdell. 3 MR. EVERDELL: Your Honor, the exhibit is marked for 4 identification as MAl1, and I'll hand up a paper copy to the 5 Court, and I believe the government has a copy, but I have 6 another one for them, as well. 7 THE COURT: Okay. I'll hear the objection. 8 MS. POMERANTZ: Thank you, your Honor. Just briefly, 9 the question posed to the defense is what is the relevance of 10 these records, and in particular, we're talking about victim 11 travel records that go over 15 years of victim travel records 12 that extend well beyond the period charged in the indictment. 13 And so, we would ask for a proffer of relevance for the 14 admissibility of such extensive travel information, private 15 information of the victims. 16 THE COURT: So no objection within the charged 17 timeframe? 18 MS. POMERANTZ: No objection. 19 MR. EVERDELL: Your Honor, for example, these records 20 go up to 2010, which was the cutoff point for the request when 21 we issued the subpoena, we, in fact, negotiated with the 22 government over how broad the subpoena would be and we agreed 23 that it would go to 2010. 24 Now, as to the relevance -- and that's why the records 25 go that far. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00016688