MR. RESNICK: Objection, Your Honor.
11 THE COURT: Grounds?
12 MR. RESNICK: They haven’t introduced
13 this into evidence yet and they’re trying to
14 testify as to the endorsement or not the
15 endorsement.
16 THE COURT: Overruled.
17 THE WITNESS: There is an endorsement
18 from Washington Mutual Bank.
19 MS. CAPOTE: Your Honor, we’d like to
20 introduce this into evidence —
21 MR. RESNICK: Your Honor —
22 MS. CAPOTE: — as part of our Composite
23 Exhibit 1.
24 THE COURT: Thank you. Before you do
25 that, what, Counsel?
MR. RESNICK: Your Honor, we object to
24 her testifying and testifying to documents.
25 She was instructed to bring with her all the
1 documents that she relied upon. She was
2 served a subpoena to do so. She’s testifying
3 as to a chain of custody which she’s telling
4 us is in some computer system which she
5 accessed that has an actual document that
6 they didn’t produce and that she apparently
7 looked at in the last week, although she
8 doesn’t know the date. We believe that’s not
9 proper in order to establish a chain of
10 custody for her to authenticate this note.
11 And we would object to it coming and being
12 used.
13 And we also object to her testifying in
14 this case, given that she was instructed to
15 come here with all of her documents that she
16 relied upon and she’s telling us, although
17 opposing counsel is saying, oh, these are the
18 only four documents, she’s now stated there
19 are other documents out there that they
20 didn’t bring and that we weren’t provided.
21 Thank you.
Trial JP Morgan Chase Heuer 11-29-2012.pdf
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