{ "document_metadata": { "page_number": "159", "document_number": "745", "date": "08/10/22", "document_type": "court transcript", "has_handwriting": false, "has_stamps": false }, "full_text": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 159 of 264 570 LC1VMAX5 Jane - cross money by testifying in the criminal case, that can affect, you know, whether or not it's an appropriate -- you know, whether the witness has an expectation that is somewhat colored by the government's plan or putting them on the stand, you know, knowing that. It's an issue of whether the witness is coming and testifying knowing that, the person who's calling them to the stand is aware of this whole plan to get more money from the civil case by testifying here. THE COURT: What does that tell us at all about her motivation? The two pieces aren't linking up. There's does she have in her mind that testifying might help her in the civil case. The answer to that is yes. I don't see -- it seems to me it's potentially -- it's attorney-client privilege issues because it's about what her attorney communicated to her. And it's hard to see any additional relevance that comes from whether the fact -- whether the government knew -- whether she knew that the government knew that she believed that -- or testifying would help her civil case, because it doesn't link up to the benefit part. So I think the first question would be fine. If the answer is yes, my inclination is not to allow the second question on both privilege, 401/403 grounds. So then the question is if the answer is no, then what do you propose? MS. MENNINGER: Your Honor, as with some of the other issues in this case, if she says no, I think that there is SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00012179", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 159 of 264 570 LC1VMAX5 Jane - cross", "position": "header" }, { "type": "printed", "content": "money by testifying in the criminal case, that can affect, you know, whether or not it's an appropriate -- you know, whether the witness has an expectation that is somewhat colored by the government's plan or putting them on the stand, you know, knowing that. It's an issue of whether the witness is coming and testifying knowing that, the person who's calling them to the stand is aware of this whole plan to get more money from the civil case by testifying here. THE COURT: What does that tell us at all about her motivation? The two pieces aren't linking up. There's does she have in her mind that testifying might help her in the civil case. The answer to that is yes. I don't see -- it seems to me it's potentially -- it's attorney-client privilege issues because it's about what her attorney communicated to her. And it's hard to see any additional relevance that comes from whether the fact -- whether the government knew -- whether she knew that the government knew that she believed that -- or testifying would help her civil case, because it doesn't link up to the benefit part. So I think the first question would be fine. If the answer is yes, my inclination is not to allow the second question on both privilege, 401/403 grounds. So then the question is if the answer is no, then what do you propose? MS. MENNINGER: Your Honor, as with some of the other issues in this case, if she says no, I think that there is", "position": "main content" }, { "type": "printed", "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300", "position": "footer" }, { "type": "printed", "content": "DOJ-OGR-00012179", "position": "footer" } ], "entities": { "people": [ "Jane", "MS. MENNINGER" ], "organizations": [ "SOUTHERN DISTRICT REPORTERS, P.C." ], "locations": [], "dates": [ "08/10/22" ], "reference_numbers": [ "1:20-cr-00330-PAE", "745", "DOJ-OGR-00012179" ] }, "additional_notes": "The document appears to be a court transcript with a discussion about a witness's testimony and potential attorney-client privilege issues. The text is mostly printed, with no visible handwriting or stamps. The footer contains the name and contact information of the reporting company and a reference number." }