{
  "document_metadata": {
    "page_number": "153",
    "document_number": "745",
    "date": "08/10/22",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-APAE Document 745 Filed 08/10/22 Page 153 of 264 564 LC1VMAX5 Jane - cross 1 MS. MENNINGER: I mean, I could start with the question of does she know whether her attorney shared that with someone else, which is the waiver question, in my mind, anyway. But the ultimate question I would like to get to is her attorney told her that. THE COURT: Right. So you want to get to a communication between attorney and client. It's privileged, right? And you're arguing that it's been waived or what are you arguing? MS. MENNINGER: Yes, I'm arguing that it's been waived because it was communicated to the government. THE COURT: Ms. Moe. MS. MOE: Thank you, your Honor. I think that question is a few moves down the chessboard. THE COURT: Could you pull up the microphone, please. MS. MOE: Yes, your Honor. I think there would be no issue with a question about this witness's understanding of whether the outcome of this case would help in a civil case or whether at the time she decided to cooperate with the government and be interviewed she thought that would help her get money in a civil case. That would be just a question about whether she had bias and motive; that wouldn't go to issues of attorney-client privilege about her general understanding. I think the question becomes, if SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00012173",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-APAE Document 745 Filed 08/10/22 Page 153 of 264 564 LC1VMAX5 Jane - cross",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 MS. MENNINGER: I mean, I could start with the question of does she know whether her attorney shared that with someone else, which is the waiver question, in my mind, anyway. But the ultimate question I would like to get to is her attorney told her that. THE COURT: Right. So you want to get to a communication between attorney and client. It's privileged, right? And you're arguing that it's been waived or what are you arguing? MS. MENNINGER: Yes, I'm arguing that it's been waived because it was communicated to the government. THE COURT: Ms. Moe. MS. MOE: Thank you, your Honor. I think that question is a few moves down the chessboard. THE COURT: Could you pull up the microphone, please. MS. MOE: Yes, your Honor. I think there would be no issue with a question about this witness's understanding of whether the outcome of this case would help in a civil case or whether at the time she decided to cooperate with the government and be interviewed she thought that would help her get money in a civil case. That would be just a question about whether she had bias and motive; that wouldn't go to issues of attorney-client privilege about her general understanding. I think the question becomes, if",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00012173",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "MS. MENNINGER",
      "MS. MOE"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "government"
    ],
    "locations": [],
    "dates": [
      "08/10/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-APAE",
      "745",
      "DOJ-OGR-00012173"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}