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  "full_text": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 17 of 264 423 LC1VMAX1\n1 MS. MODE: Yes, your Honor.\n2 Just to be clear, I think two of those topics were\n3 ones that we wanted to just confer with the witness's attorney\n4 about, because there may not be any disagreement; we just\n5 wanted to confer with him to ensure we have that right.\n6 I think there was one remaining topic that defense\n7 counsel preferred to raise as it arises during the course of\n8 cross-examination. That's what I meant by at sidebar.\n9 Apologies.\n10 THE COURT: Okay. So is there anything we can discuss\n11 now at the sidebar or no?\n12 MS. MENNINGER: There's two of the three we can\n13 discuss at sidebar. I'm happy -- if the witness's counsel\n14 wants to join us at the sidebar and weigh in on what counsel\n15 thinks is identifying or not as we discuss it.\n16 THE COURT: My preference would be for you to confer\n17 first and then let me know.\n18 MS. MODE: Yes, your Honor, that's what we would\n19 propose.\n20 THE COURT: Okay.\n21 MS. MODE: Thank you.\n22 THE COURT: All right.\n23 Anything else we can take up now?\n24 MS. MENNINGER: Yes, your Honor.\n25 I conferred with the government. We have prepared,\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00012037",
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      "content": "1 MS. MODE: Yes, your Honor.\n2 Just to be clear, I think two of those topics were\n3 ones that we wanted to just confer with the witness's attorney\n4 about, because there may not be any disagreement; we just\n5 wanted to confer with him to ensure we have that right.\n6 I think there was one remaining topic that defense\n7 counsel preferred to raise as it arises during the course of\n8 cross-examination. That's what I meant by at sidebar.\n9 Apologies.\n10 THE COURT: Okay. So is there anything we can discuss\n11 now at the sidebar or no?\n12 MS. MENNINGER: There's two of the three we can\n13 discuss at sidebar. I'm happy -- if the witness's counsel\n14 wants to join us at the sidebar and weigh in on what counsel\n15 thinks is identifying or not as we discuss it.\n16 THE COURT: My preference would be for you to confer\n17 first and then let me know.\n18 MS. MODE: Yes, your Honor, that's what we would\n19 propose.\n20 THE COURT: Okay.\n21 MS. MODE: Thank you.\n22 THE COURT: All right.\n23 Anything else we can take up now?\n24 MS. MENNINGER: Yes, your Honor.\n25 I conferred with the government. We have prepared,",
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    "people": [
      "MS. MODE",
      "THE COURT",
      "MS. MENNINGER"
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      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
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      "745",
      "DOJ-OGR-00012037"
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