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    "page_number": "45",
    "document_number": "465",
    "date": "11/15/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 45 of 127 LB15MAX2 45 says, your Honor. I agree that these are issues that it's important for the Court to be aware of before trial but I can't predict, and I'm not really sure that the government can predict, what their witnesses will say or suggest in their actual testimony. When they open the door through fronting it, it may be that they say something that suggests that there was someone who believed them, that there was a victims' compensation fund that believed them. If those kinds of words are used by the witness, then that becomes problematic in terms of our ability to be hamstrung in cross-examination that there was no actual confrontation during that process. So, depending upon what the witnesses say we would re-raise this but I do think it's important for the Court to sort of have that in mind when the government is trying to use evidence to front an issue but then potentially opening the door to us being open to cross on the same type of language that their witnesses used. THE COURT: Ms. Moe? MS. MOE: Your Honor, again, the government doesn't anticipate that the testimony would come out that way but, in any event, I think with respect to the specific concern defense counsel has raised, to the extent it opened the door I don't believe it would open the door to separate collateral issues about a separate civil lawsuit and resolution of that civil lawsuit. THE COURT: Yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007096",
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      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 45 of 127 LB15MAX2 45",
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      "type": "printed",
      "content": "says, your Honor. I agree that these are issues that it's important for the Court to be aware of before trial but I can't predict, and I'm not really sure that the government can predict, what their witnesses will say or suggest in their actual testimony. When they open the door through fronting it, it may be that they say something that suggests that there was someone who believed them, that there was a victims' compensation fund that believed them. If those kinds of words are used by the witness, then that becomes problematic in terms of our ability to be hamstrung in cross-examination that there was no actual confrontation during that process. So, depending upon what the witnesses say we would re-raise this but I do think it's important for the Court to sort of have that in mind when the government is trying to use evidence to front an issue but then potentially opening the door to us being open to cross on the same type of language that their witnesses used.",
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    {
      "type": "printed",
      "content": "THE COURT: Ms. Moe?",
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      "type": "printed",
      "content": "MS. MOE: Your Honor, again, the government doesn't anticipate that the testimony would come out that way but, in any event, I think with respect to the specific concern defense counsel has raised, to the extent it opened the door I don't believe it would open the door to separate collateral issues about a separate civil lawsuit and resolution of that civil lawsuit.",
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      "type": "printed",
      "content": "THE COURT: Yes.",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007096",
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      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "11/15/21"
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