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  "full_text": "Case 1:20-cr-00330-PAE Document 747 Filed 08/10/22 Page 74 of 228 LC2VMAX2 Rocchio - Direct her explain, as an expert, opinions, undisclosed opinions, regarding some of those issues. And I can't tell yet from your proffer whether you're trying to do the former or the latter or -- MR. PAGLIUCA: I'm not going to ask her for any opinions, your Honor. I'm going to be using leading questions throughout all of this. So there will be no -- THE COURT: Well -- MR. PAGLIUCA: -- opportunity for her to give an opinion other than yes or no. THE COURT: Well, we'll see about that. MR. PAGLIUCA: I understand. Of course. 611 allows you to control the examination 100 percent, your Honor, and I get that. But I don't intend to, I guess that's the answer to the Court's question. THE COURT: Ms. Pomerantz? MS. POMERANTZ: Your Honor -- THE COURT: So in terms of -- let's just start with scope, if we could. So to the extent she's testified around her opinions regarding delayed disclosure in this context, is it fair cross-examination and within the scope of that to suggest that there are other reasons for delayed disclosure? MS. POMERANTZ: Your Honor, may I just have one moment? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00012359",
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      "content": "her explain, as an expert, opinions, undisclosed opinions, regarding some of those issues. And I can't tell yet from your proffer whether you're trying to do the former or the latter or -- MR. PAGLIUCA: I'm not going to ask her for any opinions, your Honor. I'm going to be using leading questions throughout all of this. So there will be no -- THE COURT: Well -- MR. PAGLIUCA: -- opportunity for her to give an opinion other than yes or no. THE COURT: Well, we'll see about that. MR. PAGLIUCA: I understand. Of course. 611 allows you to control the examination 100 percent, your Honor, and I get that. But I don't intend to, I guess that's the answer to the Court's question. THE COURT: Ms. Pomerantz? MS. POMERANTZ: Your Honor -- THE COURT: So in terms of -- let's just start with scope, if we could. So to the extent she's testified around her opinions regarding delayed disclosure in this context, is it fair cross-examination and within the scope of that to suggest that there are other reasons for delayed disclosure? MS. POMERANTZ: Your Honor, may I just have one moment?",
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