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  "full_text": "Case 1:20-cr-00330-PAE Document 782 Filed 01/15/25 Page 100 of 158 100 LBAAMAX3ps Rocchio - Cross 1 A. I haven't tabulated them. I, I could make an estimate if you like, but I -- 2 Q. Sure. 3 A. -- don't know for sure. 4 About 25. 5 6 Q. 25 hours. 7 And do you keep time records of what you do? 8 A. I do. 9 MR. PAGLIUCA: I'd ask for production of those time 10 records, your Honor. 11 It doesn't have to be today. 12 THE COURT: On what grounds? 13 MR. PAGLIUCA: Well, your Honor, it goes to the motive 14 and bias of the witness, as a financial gain through this 15 contract. 16 THE COURT: It's a perfectly acceptable question in 17 front of the jury. But what's your entitlement to the time 18 records? 19 MR. PAGLIUCA: So we know how much time she's spent on 20 this and what her anticipated compensation is. 21 THE COURT: I'm just asking, I mean, this sounds like 22 broad-reaching discovery. Under what rule or other authority 23 are you entitled to that? 24 MR. PAGLIUCA: I believe, your Honor, I'm entitled to 25 this under Brady and Giglio, because this is motive and bias  SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014976",
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      "content": "1 A. I haven't tabulated them. I, I could make an estimate if you like, but I -- 2 Q. Sure. 3 A. -- don't know for sure. 4 About 25. 5 6 Q. 25 hours. 7 And do you keep time records of what you do? 8 A. I do. 9 MR. PAGLIUCA: I'd ask for production of those time 10 records, your Honor. 11 It doesn't have to be today. 12 THE COURT: On what grounds? 13 MR. PAGLIUCA: Well, your Honor, it goes to the motive 14 and bias of the witness, as a financial gain through this 15 contract. 16 THE COURT: It's a perfectly acceptable question in 17 front of the jury. But what's your entitlement to the time 18 records? 19 MR. PAGLIUCA: So we know how much time she's spent on 20 this and what her anticipated compensation is. 21 THE COURT: I'm just asking, I mean, this sounds like 22 broad-reaching discovery. Under what rule or other authority 23 are you entitled to that? 24 MR. PAGLIUCA: I believe, your Honor, I'm entitled to 25 this under Brady and Giglio, because this is motive and bias",
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