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    "page_number": "48",
    "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 48 of 127 48 LB15MAX2\n\n1 so, just as we were arguing earlier, your Honor, if the government is trying to put on evidence about other people being victims, then that opens the door to us challenging that other person's credibility. I don't have any issue with the way we briefed it which was it just depends on what is said by the witness and we will certainly re-raise these issues. But, the government can't have their cake and eat it, too. If they want to put on evidence about a broad number of supposed victims then we have the obligation, ethically, to challenge whether or not those other individuals are in fact victims.\n\nTHE COURT: Well, I think maybe speaking in the abstract is where the fine points get lost. So if a testifying witness testifies about something that she observed involving the defendant and another individual, that doesn't open the door to attacking the credibility of that other individual.\n\nAgree to that basic premise?\n\nMS. MENNINGER: Correct, your Honor; an observation alone.\n\nTHE COURT: And if the witness testifies that another individual, using the name or pseudonym -- if that is what is appropriate in light of the Court's ruling, I don't have it firmly in mind at this point but, just as an example: Someone told me to go to somebody's home. That doesn't put the credibility of the out-of-court witness in issue, does it?\n\nBecause that is not being offered for the truth. Now, if it\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007099",
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      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 48 of 127 48 LB15MAX2",
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      "type": "printed",
      "content": "1 so, just as we were arguing earlier, your Honor, if the government is trying to put on evidence about other people being victims, then that opens the door to us challenging that other person's credibility. I don't have any issue with the way we briefed it which was it just depends on what is said by the witness and we will certainly re-raise these issues. But, the government can't have their cake and eat it, too. If they want to put on evidence about a broad number of supposed victims then we have the obligation, ethically, to challenge whether or not those other individuals are in fact victims.",
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    {
      "type": "printed",
      "content": "THE COURT: Well, I think maybe speaking in the abstract is where the fine points get lost. So if a testifying witness testifies about something that she observed involving the defendant and another individual, that doesn't open the door to attacking the credibility of that other individual.",
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      "type": "printed",
      "content": "Agree to that basic premise?",
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      "type": "printed",
      "content": "MS. MENNINGER: Correct, your Honor; an observation alone.",
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      "type": "printed",
      "content": "THE COURT: And if the witness testifies that another individual, using the name or pseudonym -- if that is what is appropriate in light of the Court's ruling, I don't have it firmly in mind at this point but, just as an example: Someone told me to go to somebody's home. That doesn't put the credibility of the out-of-court witness in issue, does it?",
      "position": "main content"
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      "type": "printed",
      "content": "Because that is not being offered for the truth. Now, if it",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007099",
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      "MS. MENNINGER"
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      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "11/15/21"
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      "465",
      "DOJ-OGR-00007099"
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