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    "page_number": "156",
    "document_number": "745",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 156 of 264 LC1VMAX5 Jane - cross 1 he mentioned he told her it would help her case? 2 MS. MENNINGER: Yes, your Honor. Because prior to 3 that line, he's disclosing that he discussed whether 4 cooperating with the case and then ultimately gets to the 5 question of testifying in the case, he says, were the morally 6 right thing to do. And they had discussed how testifying at 7 trial was the right thing to do. He also mentioned that he had 8 told her it would help her case. It is slightly ambiguous. I 9 don't know if it refers back to the entirety of the things said 10 before it, but that's what the email or the note says. 11 THE COURT: Okay. So you want to ask her if she had 12 any basis to conclude that her participation as a witness here 13 would help her civil litigation recovery prospects. 14 MS. MENNINGER: Right, your Honor. If it were a 15 cooperation agreement and a witness had cooperated and someone 16 had promised that they would get a lesser sentence if they 17 cooperated, I can see that also being admissible. So maybe 18 just the -- 19 THE COURT: The attorney's advice to the client about 20 whether they should take a plea and what assistance that might 21 get them and all of that obviously is privileged. 22 MS. MENNINGER: It is, until you disclose it to the 23 government. I totally agree with that, your Honor. 24 THE COURT: Okay. So then the question is if she 25 answers yes to that question, I had some reason to believe that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00017765",
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      "content": "LC1VMAX5 Jane - cross",
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      "content": "1 he mentioned he told her it would help her case? 2 MS. MENNINGER: Yes, your Honor. Because prior to 3 that line, he's disclosing that he discussed whether 4 cooperating with the case and then ultimately gets to the 5 question of testifying in the case, he says, were the morally 6 right thing to do. And they had discussed how testifying at 7 trial was the right thing to do. He also mentioned that he had 8 told her it would help her case. It is slightly ambiguous. I 9 don't know if it refers back to the entirety of the things said 10 before it, but that's what the email or the note says. 11 THE COURT: Okay. So you want to ask her if she had 12 any basis to conclude that her participation as a witness here 13 would help her civil litigation recovery prospects. 14 MS. MENNINGER: Right, your Honor. If it were a 15 cooperation agreement and a witness had cooperated and someone 16 had promised that they would get a lesser sentence if they 17 cooperated, I can see that also being admissible. So maybe 18 just the -- 19 THE COURT: The attorney's advice to the client about 20 whether they should take a plea and what assistance that might 21 get them and all of that obviously is privileged. 22 MS. MENNINGER: It is, until you disclose it to the 23 government. I totally agree with that, your Honor. 24 THE COURT: Okay. So then the question is if she 25 answers yes to that question, I had some reason to believe that",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00017765",
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}