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    "page_number": "4",
    "document_number": "739",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 739 Filed 08/10/22 Page 4 of 43 4 LBNAMAXTps\n\n1 MS. COMEY: Your Honor, I can assure you we've\n2 attempted to. We raised issues that we thought are clearly not\n3 proper ground for cross-examination, like arrests as a juvenile\n4 for curfew violations, misdemeanor convictions that are more\n5 than ten years old, things that have nothing do with\n6 credibility, and the defense told us that they cannot assure us\n7 that they will not raise those issues on cross. We obviously\n8 need a pretrial ruling so that we know whether we have to raise\n9 those things on direct to draw the sting.\n10 MR. PAGLIUCA: Your Honor, this is not a surprise to\n11 me that this is being raised, but this is a surprising issue, I\n12 think, to be raised. The list, laundry list of things that the\n13 government wants to talk about include things that are clearly\n14 within the rules, and --\n15 THE COURT: I don't want a speech. What I want, it\n16 sounds like they're saying there are things that are clearly\n17 outside of the rules, in their view. And you say there are\n18 things that are clearly within the rules. You'll have a\n19 mature, reasonable discussion, and come to some agreement where\n20 agreement can be had. When you have disputes that are good\n21 faith and reasonable and based on available interpretations of\n22 the law, you'll submit to me in writing and I'll be happy to\n23 resolve it.\n24 MR. PAGLIUCA: That's totally fine, your Honor. I\n25 guess the problem is -- and this is where we're going to end\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00011625",
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      "content": "Case 1:20-cr-00330-PAE Document 739 Filed 08/10/22 Page 4 of 43 4 LBNAMAXTps",
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      "content": "1 MS. COMEY: Your Honor, I can assure you we've\n2 attempted to. We raised issues that we thought are clearly not\n3 proper ground for cross-examination, like arrests as a juvenile\n4 for curfew violations, misdemeanor convictions that are more\n5 than ten years old, things that have nothing do with\n6 credibility, and the defense told us that they cannot assure us\n7 that they will not raise those issues on cross. We obviously\n8 need a pretrial ruling so that we know whether we have to raise\n9 those things on direct to draw the sting.\n10 MR. PAGLIUCA: Your Honor, this is not a surprise to\n11 me that this is being raised, but this is a surprising issue, I\n12 think, to be raised. The list, laundry list of things that the\n13 government wants to talk about include things that are clearly\n14 within the rules, and --\n15 THE COURT: I don't want a speech. What I want, it\n16 sounds like they're saying there are things that are clearly\n17 outside of the rules, in their view. And you say there are\n18 things that are clearly within the rules. You'll have a\n19 mature, reasonable discussion, and come to some agreement where\n20 agreement can be had. When you have disputes that are good\n21 faith and reasonable and based on available interpretations of\n22 the law, you'll submit to me in writing and I'll be happy to\n23 resolve it.\n24 MR. PAGLIUCA: That's totally fine, your Honor. I\n25 guess the problem is -- and this is where we're going to end",
      "position": "main"
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011625",
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  "entities": {
    "people": [
      "MS. COMEY",
      "MR. PAGLIUCA",
      "THE COURT"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
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      "1:20-cr-00330-PAE",
      "739",
      "DOJ-OGR-00011625"
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}