Louis Ziskin

I am going to give you, you have to make a prima facie showing of these things.

I'm going to give you the head of wiretaps, John Rakowski, and your case agent, Bill Weinhen, and we are going to have an evidentiary hearing, and you're going to do this step by step.

Now, at the same time, I've been hitting them with the wiretap because I found a discrepancy on the, when they get a wiretap from a judge, they say, hey, judge, we want to tap Matt Cox's phone because he's selling dope.

And so they got after they get that warrant with 30, 60, 90 days, whatever it is, they've got to make a 10 day report contemporaneously to the judge.

Hey, judge, first 10 days, we had eight drug calls and this was a total amount of calls.

And here's a summary of some of the drug calls and we're making progress.

right?

So then when the wiretap's done, right, they have an optical disc, they hand it to, you know, they give it, they seal the original recording, supposedly, according to Title III, and they give you a copy, and now you've got the wiretap, you have the 10-day reports, which are part of discovery, and you have something called line sheets, which are synopsises.

And then later, you get the transcripts, like I was talking about, that I found in that notebook, just so happened they had all those transcripts before my first trial, so they knew that, right?

So I'm telling the judge, look, Your Honor, here's what they told the judge, and here's what we have in the actual wiretap.

On eight different days, there's 21 more calls minimized than there was during the 10-day report.

Title III says you can't have equipment that can add, edit, alter, delete, or erase, so...

What's up?

Now, I couldn't identify.

I knew which calls it was, but I just know on on eight days there's 21 more call.

I can't tell you which ones they with, but there's a problem on eight days with 21 calls.

Right.

So that's also happening at the same time that I make this motion.

Best evidence ruled that.

So the government needs to be disqualified.