{ "document_metadata": { "page_number": "5", "document_number": "536", "date": "12/10/21", "document_type": "court transcript", "has_handwriting": false, "has_stamps": false }, "full_text": "Case 1:20-cr-00330-PAE Document 536 Filed 12/10/21 Page 5 of 43 5 LBNAMAXTps\n1 up, which is why I'm telling you this now -- we can't predict\n2 what people are going to say on either direct or cross-examination. And of course we will follow the rules.\n3 But here's an example: If someone were to say on direct\n4 examination, \"I've never been in trouble in my entire life,\"\n5 well, then that opens up the whole panoply of what is or is not\n6 permissible under Rule 609.\n7\n8 And so that's where we end up here. And I think,\n9 frankly, these are not issues that need to be briefed. These\n10 are issues that simply come up during trial, and if someone\n11 does something that one side or the other thinks is not\n12 appropriate, there's an objection and it's resolved. I can\n13 assure you that we are not going to do anything that is outside\n14 of the rules, and if we think it's even close, we would of\n15 course approach and address the issue with the Court.\n16 If the government wants, I am happy to confer more\n17 about this. If the government wants to brief it, they can.\n18 But I think we end up in that place, which is, these are\n19 trial-time decisions.\n20 THE COURT: That may be true, and I suspect if you\n21 have a conversation where the government says, you can't raise\n22 under the rule a juvenile conviction for -- what was it?\n23 MS. COMEY: A curfew violation, your Honor.\n24 THE COURT: -- a curfew violation, and you say, well,\n25 of course it could be that they say, I've never been in trouble\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cr-00330-PAE Document 536 Filed 12/10/21 Page 5 of 43 5 LBNAMAXTps", "position": "header" }, { "type": "printed", "content": "up, which is why I'm telling you this now -- we can't predict what people are going to say on either direct or cross-examination. And of course we will follow the rules. But here's an example: If someone were to say on direct examination, \"I've never been in trouble in my entire life,\" well, then that opens up the whole panoply of what is or is not permissible under Rule 609. And so that's where we end up here. And I think, frankly, these are not issues that need to be briefed. These are issues that simply come up during trial, and if someone does something that one side or the other thinks is not appropriate, there's an objection and it's resolved. I can assure you that we are not going to do anything that is outside of the rules, and if we think it's even close, we would of course approach and address the issue with the Court. If the government wants, I am happy to confer more about this. If the government wants to brief it, they can. But I think we end up in that place, which is, these are trial-time decisions.", "position": "main" }, { "type": "printed", "content": "THE COURT: That may be true, and I suspect if you have a conversation where the government says, you can't raise under the rule a juvenile conviction for -- what was it? MS. COMEY: A curfew violation, your Honor. THE COURT: -- a curfew violation, and you say, well, of course it could be that they say, I've never been in trouble", "position": "main" }, { "type": "printed", "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300", "position": "footer" } ], "entities": { "people": [ "MS. COMEY" ], "organizations": [ "SOUTHERN DISTRICT REPORTERS, P.C." ], "locations": [], "dates": [ "12/10/21" ], "reference_numbers": [ "1:20-cr-00330-PAE", "536" ] }, "additional_notes": "The document appears to be a court transcript with clear and legible text. There are no visible redactions or damage." }