DOJ-OGR-00017821.json 4.3 KB

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  3. "page_number": "212",
  4. "document_number": "745",
  5. "date": "08/10/22",
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  10. "full_text": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 212 of 264 623 LC1Qmax6 Jane - Redirect that, but again, we're talking about a number of conversations during this time period. That's my current expectation. But I think with respect to I think some of the granular issues, the difference between woman and girls, I think, especially in this context is not so different that it would not be a prior consistent statement. And beyond that, your Honor, we think this tracks the rule. MS. STERNHEIM: Judge, I disagree. The distinction between a girl and a woman is precisely what this case is about, and she was very clear that she felt like she was the only one. The other people were women. THE COURT: She said she didn't know what their ages were. MS. STERNHEIM: She didn't know their ages, but she did not refer to them as girls. THE COURT: But wasn't the recent testimony, I think it was on cross, which was: Were there underage girls. And she said, \"I wouldn't know the ages.\" MS. STERNHEIM: That's fine, but to call them girls connotes that they are minors, and that parlays right into the government's theory of the case, and they're bringing it out through a witness whose sole purpose is substantiated prior consistent statement, and that is not consistent with the testimony that we've heard. If he wants to say there were prior women, I can't SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00017821",
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  14. "content": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 212 of 264 623 LC1Qmax6 Jane - Redirect",
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  19. "content": "that, but again, we're talking about a number of conversations during this time period. That's my current expectation. But I think with respect to I think some of the granular issues, the difference between woman and girls, I think, especially in this context is not so different that it would not be a prior consistent statement. And beyond that, your Honor, we think this tracks the rule.",
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  24. "content": "MS. STERNHEIM: Judge, I disagree. The distinction between a girl and a woman is precisely what this case is about, and she was very clear that she felt like she was the only one. The other people were women.",
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  29. "content": "THE COURT: She said she didn't know what their ages were.",
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  34. "content": "MS. STERNHEIM: She didn't know their ages, but she did not refer to them as girls.",
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  39. "content": "THE COURT: But wasn't the recent testimony, I think it was on cross, which was: Were there underage girls. And she said, \"I wouldn't know the ages.\"",
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  44. "content": "MS. STERNHEIM: That's fine, but to call them girls connotes that they are minors, and that parlays right into the government's theory of the case, and they're bringing it out through a witness whose sole purpose is substantiated prior consistent statement, and that is not consistent with the testimony that we've heard.",
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  49. "content": "If he wants to say there were prior women, I can't",
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  54. "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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  59. "content": "DOJ-OGR-00017821",
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  65. "MS. STERNHEIM"
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  68. "SOUTHERN DISTRICT REPORTERS, P.C."
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  72. "08/10/22"
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  76. "745",
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