In a letter submitted in United States v. Combs, 24-cr-542 (AS), the defense provides additional legal support for its objection to the admission of Government Exhibit GX A-629-A. The prosecution introduced the exhibit on the basis that it contained statements made by Mr. Combs’s head of security, known as “Uncle Pauly,” and argued they were admissible under Federal Rule of Evidence 801(d)(2)(D), which allows for the admission of statements made by an agent or employee concerning a matter within the scope of that relationship. However, during proceedings, the Court questioned whether the statements qualified under that rule, prompting the defense to elaborate on its position.

The defense argues that the statements in GX A-629-A fall outside the bounds of Uncle Pauly’s agency relationship with Mr. Combs and therefore cannot be considered admissible under the cited rule. Specifically, the defense contends that the content of the statements does not pertain to matters within the scope of Uncle Pauly’s responsibilities as head of security. Because Rule 801(d)(2)(D) only permits statements concerning an agent’s authorized duties, the defense insists that the exhibit should be excluded from evidence, reinforcing its objection with legal precedent to support its interpretation.

In our second document...

In a letter addressed to Judge Subramanian, the Government urges the Court to formally admit Exhibit GX 10C-114 into evidence, rather than limiting its use to that of a demonstrative aid. The Government argues that the content and context of the exhibit meet the necessary legal standards for admissibility and are directly relevant to the case at hand. They likely emphasize that the exhibit has probative value that outweighs any prejudicial effect, and that it provides substantive evidence supporting the Government’s case.


The request to elevate GX 10C-114 from a demonstrative to an official exhibit suggests that the Government views this piece of evidence as crucial for jury consideration during deliberations. While demonstratives are typically used to help explain or visualize other admitted evidence, they are not sent back with the jury. By seeking its admission as an exhibit, the prosecution signals its intent to ensure the jury has access to this material during deliberations, reinforcing its evidentiary weight and importance in establishing elements of the charged offenses.



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source:

gov.uscourts.nysd.628425.363.0.pdf

gov.uscourts.nysd.628425.375.0.pdf

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