Case File
efta-efta01250081DOJ Data Set 9OtherDS9 Document EFTA01250081
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DOJ Data Set 9
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efta-efta01250081
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From:
(USANYS) <
Sent: Wednesday, April 28, 2021 7:43 PM
To:
((BANN'S) <
),
Subject: Notes from Witness Prep with Leslie Fagin
4/28/21
Leslie Fagin
Martin Druyer
EL
Witness Prep with Leslie Fagin
Martin expressed concern about spending too much time waiting in the courtroom because LF isn't salaried, so needs
the time to work. LF is willing to testify, though would rather this be stipulated.
LF doesn't personally have a copy of the transcript, but if her name is on it, she was the reporter. After she signs it, she
sends it off to production to get printed and sent to whoever has a copy. She assumes her agency (Magna) keeps an
archived copy and they send the original to 85F, but she's not sure.
The transcript has a certification at the end of every transcript that LF takes, in which she certifies the truth and
accuracy.
Not sure whether LF has access to her agency's files.
LF can't identify a page of a transcript in isolation. She doesn't have a particular process normally to determine the truth
and accuracy of the contents of a transcript later — isn't really asked. To figure out whether or not a transcript is
doctored, LF could compare side by side the version Magna has and the exhibit. Though she's never been asked to do
this in her 34 years.
3501.488-001
Page 1 of 2
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00096051
EFTA01250081
LF takes down testimony, comes home, edits it, sends it to Magna with her cert page at the end, and that's the end of
the process. Her cert says that she certifies the transcript and it's true and accurate.
Not sure she has her notes still. Maybe on the cloud somewhere. Note that LF's stenographic notes, if they exist, aren't
themselves in the transcript, and so may diverge from the final transcript she wrote and sent to Magna because the
notes were produced and edited into the final transcript.
2
3501.488-001
Page 2 of 2
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00096052
EFTA01250082
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