November 3, 2021¶
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Prepared for trial testimony. previously undisclosed, clarifying, or different recollections/information below:
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Estimates speaking with JE 6 or more times on the phone; understood JE was boss; when JE called, he would talk about how impressed he was and wanted to help open doors for wanted them to have opportunities like he provided for other students
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remembers certain details more clearly than others; has had a lot going on in the past few years; not exactly sure on some dates
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When JE called the first time, remembers she was running the vacuum
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understood that was raising money for the trip to JE also told that he was contributing money to the trip
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understood that JE helped a lot of students, was interested in helping students to get into other schools
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Approximately a couple of weeks between call and trip to New Mexico
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JE told that students would be staying in cabins in NM; JE told that he wanted to go to NM to join other students who were traveling abroad; told him that she could not afford additional expenses; JE said he would be paying for all expenses for all the students
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thinks had not yet decided where she was going to go that summer; saw NM as an opportunity for her to get information from other students
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had been to NM for some; had talked to about that and shown her photos from NM; thought trip to NM for would be similar but for a different age group and for students looking to travel abroad
3515-007¶
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
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SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7,8,9,10,15,and 17¶
EFTA_00007913¶
EFTA00158823¶