In the case of United States v. Combs, S3 24 Cr. 542 (AS), the Government filed a letter opposing the defendant's objections to certain exhibits intended to be introduced during the testimony of the witness identified as “Jane.” Despite ongoing discussions between the parties, two main areas of dispute remain. First, the defense argues that selected text message exchanges should be excluded under the rule of completeness, suggesting that the Government is presenting messages out of context. Second, the defense raises hearsay objections to specific exhibits, including a text message exchange, a screenshot of a media headline, and several personal notes written by Jane in her phone’s Notes app.

The Government maintains that these objections lack merit. Regarding the completeness argument, the prosecution contends that the messages they seek to introduce are independently admissible and not misleading or taken out of context. As for the hearsay objections, the Government argues that the exhibits in question either do not constitute hearsay, fall within recognized exceptions, or are not offered for the truth of the matter asserted. Ultimately, the Government urges the Court to overrule the objections and allow the contested materials to be admitted into evidence during Jane’s testimony.


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source:

gov.uscourts.nysd.628425.411.0_1.pdf