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  "full_text": "Case 1:20-cr-00330-PAE Document 529 Filed 12/08/21 Page 14 of 18 LBF3MAXC 14\n1 understanding that the government will provide notice to the victims today, and will file any -- I suppose at that point you\n2 could phrase it as a motion to quash the subpoena by Wednesday. Defense response by Friday. Okay. All right.\n5 Yes, Ms. Comey.\n6 MS. COMEY: Yes, your Honor. Two issues we wanted to bring up for your Honor. We've been working with defense\n7 counsel to reach points of agreement, and have reached stipulations as to certain pieces of evidence. But there are\n8 certain pieces of evidence where we believe we may need to brief authentication for your Honor. Particularly, there are\n9 certain birth certificates and a prior sworn statement that we think we need to brief. We have been conferring with defense\n10 counsel, I don't think we are going to reach agreement, so we'd like to set a schedule for the briefing on that.\n11 And the other issue we wanted to put on your Honor's radar but that does not need a briefing schedule at this point I believe, is we plan to confer with defense counsel about areas that we believe would be improper for cross-examination of government witnesses. Usually we can reach agreement on those, but if we can't reach agreement, then we will need to brief that with your Honor.\n23 THE COURT: Okay. So what do you propose for the authentication issues?\n24 MS. COMEY: We would propose that the government\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00008258",
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      "content": "1 understanding that the government will provide notice to the victims today, and will file any -- I suppose at that point you\n2 could phrase it as a motion to quash the subpoena by Wednesday. Defense response by Friday. Okay. All right.\n5 Yes, Ms. Comey.\n6 MS. COMEY: Yes, your Honor. Two issues we wanted to bring up for your Honor. We've been working with defense\n7 counsel to reach points of agreement, and have reached stipulations as to certain pieces of evidence. But there are\n8 certain pieces of evidence where we believe we may need to brief authentication for your Honor. Particularly, there are\n9 certain birth certificates and a prior sworn statement that we think we need to brief. We have been conferring with defense\n10 counsel, I don't think we are going to reach agreement, so we'd like to set a schedule for the briefing on that.\n11 And the other issue we wanted to put on your Honor's radar but that does not need a briefing schedule at this point I believe, is we plan to confer with defense counsel about areas that we believe would be improper for cross-examination of government witnesses. Usually we can reach agreement on those, but if we can't reach agreement, then we will need to brief that with your Honor.\n23 THE COURT: Okay. So what do you propose for the authentication issues?\n24 MS. COMEY: We would propose that the government",
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