112 H3vlgiu2 ih been prepared by the state's attorney's office but he didn't 2 know. So what happens then with this transcript is, there is 3 an attempt at a deposition of Ms. Hall in Miami, this summer, 4 and Ms. Hall comes in and she sits down, and she doesn't want 5 to answer any questions about anything, and she says, I don't 6 remember anything about any of this. Her lawyer says, she 7 doesn't remember anything about any of this and she spent the 8 last ten years forgetting about all of this and she's not going 9 to remember anything about this. Mr. Edwards then puts the 10 transcript in front of her and she doesn't look at it. She 1a doesn't even look at the transcript. She doesn't turn the 12 page. She doesn't read any of it. There's a question asked at 13 some point later: Isn't it true that everything you said in 14 the police department was true? And then shortly after that, 15 the deposition ends. And they're trying to say that that is a 16 sufficient factual basis and an evidentiary basis for the de admission of this transcript, which is, you know, unsponsored 18 hearsay. 19 There's a similar problem with this recording because 20 Ms. Hall never listened to the recording, never authenticated 21 the recording. And so there's no evidence whatsoever that it's 22 Ms. Hall's statement or that it was subject to any 23 cross-examination. 24 So to try to get around all of these evidentiary 25 problems, now what's being advanced by the plaintiffs is, well, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011415