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- "full_text": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 210 of 264 621 LC1Qmax6 Jane - Redirect 1 MS. STERNHEIM: Right. 2 THE COURT: Okay. Can you confer? 3 MS. MOE: Yes, your Honor. 4 THE COURT: During the break? 5 MS. STERNHEIM: Of course. 6 THE COURT: Great. I appreciate you raising it, and let me know if there's disagreement. Thank you. 8 MS. STERNHEIM: Will do. 9 THE COURT: We'll break for ten. 10 (Recess) 11 (Jurors not present) 12 THE COURT: Matters to take up? 13 MS. MOE: Not from the government your Honor. 14 MS. STERNHEIM: Just very briefly, Judge. I did have an opportunity to confer with Ms. Moe. I just want to state for the record, with regard to the introduction of prior consistent statements, it is my understanding that there needs to be a similar exactitude as one would have with prior inconsistent statements, and I understand that the government is offering their next witness, Matt, to establish the fact that there was some colloquy discussion between Matt and Jane at an earlier time before this. I have no problem with that. 23 The issue is that, at least in the 3500 material, the statements that Matt made are not -- they don't dovetail entirely with what went on on the direct examination. One 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00012230",
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- "content": "1 MS. STERNHEIM: Right. 2 THE COURT: Okay. Can you confer? 3 MS. MOE: Yes, your Honor. 4 THE COURT: During the break? 5 MS. STERNHEIM: Of course. 6 THE COURT: Great. I appreciate you raising it, and let me know if there's disagreement. Thank you. 8 MS. STERNHEIM: Will do. 9 THE COURT: We'll break for ten. 10 (Recess) 11 (Jurors not present) 12 THE COURT: Matters to take up? 13 MS. MOE: Not from the government your Honor. 14 MS. STERNHEIM: Just very briefly, Judge. I did have an opportunity to confer with Ms. Moe. I just want to state for the record, with regard to the introduction of prior consistent statements, it is my understanding that there needs to be a similar exactitude as one would have with prior inconsistent statements, and I understand that the government is offering their next witness, Matt, to establish the fact that there was some colloquy discussion between Matt and Jane at an earlier time before this. I have no problem with that. 23 The issue is that, at least in the 3500 material, the statements that Matt made are not -- they don't dovetail entirely with what went on on the direct examination. One",
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