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- "full_text": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 158 of 264 569 LC1VMAX5 Jane - cross 1 the question is, Are you aware that your attorney made a statement to the government about his conversation with you 2 about your expected outcome in the case. 3 4 THE COURT: Well, okay. At the first step, you agree 5 they can ask if she had any basis to believe that her 6 participation as a witness here would have any impact on her 7 potential compensation in civil litigation. You don't object 8 to that question? 9 MS. MOE: No, your Honor, no objection. 10 THE COURT: So then we have what if she says yes and 11 what if she says no. So if she says yes, their follow-up 12 question is, Are you aware that your attorney told the 13 government that? 14 I think I agree with you. I don't know what the 15 relevance of that is. And it is an attorney-client 16 communication. 17 What's the relevance of whether she knows her attorney 18 told the government that? 19 MS. MENNINGER: Your Honor, I think it gets into her 20 expectations that she -- that the government knows that she 21 knows. And so at that point she's testifying with an 22 expectation that -- you know, if the government doesn't -- is 23 unaware of her attorney's advice, then it's just a secret 24 between her and her attorney. But if the government who is 25 calling her to testify is aware of her plan, intent to get more SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00017767",
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- "content": "1 the question is, Are you aware that your attorney made a statement to the government about his conversation with you 2 about your expected outcome in the case. 3 4 THE COURT: Well, okay. At the first step, you agree 5 they can ask if she had any basis to believe that her 6 participation as a witness here would have any impact on her 7 potential compensation in civil litigation. You don't object 8 to that question? 9 MS. MOE: No, your Honor, no objection. 10 THE COURT: So then we have what if she says yes and 11 what if she says no. So if she says yes, their follow-up 12 question is, Are you aware that your attorney told the 13 government that? 14 I think I agree with you. I don't know what the 15 relevance of that is. And it is an attorney-client 16 communication. 17 What's the relevance of whether she knows her attorney 18 told the government that? 19 MS. MENNINGER: Your Honor, I think it gets into her 20 expectations that she -- that the government knows that she 21 knows. And so at that point she's testifying with an 22 expectation that -- you know, if the government doesn't -- is 23 unaware of her attorney's advice, then it's just a secret 24 between her and her attorney. But if the government who is 25 calling her to testify is aware of her plan, intent to get more",
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