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- "full_text": "Case 1:20-cr-00330-PAE Document 739 Filed 08/10/22 Page 7 of 43 7 LBNAMAXTps because of the obvious issue that would arise with attorney-client privilege and with Minor Victim 4's right to representation of counsel. MR. PAGLIUCA: Well, first, your Honor, I don't think that it's appropriate for me to have to discuss defense strategy in this context. However -- THE COURT: That's fine. There will be no -- without briefing, you will not call an attorney for a witness, period. I'm happy to see briefing, but until that happens, you won't. MR. PAGLIUCA: That's fine, your Honor. THE COURT: OK. MS. COMEY: Thank you, your Honor. We had one other question for your Honor, which is whether the Court intends to, in its preliminary instruction, inform the jury that certain witnesses will be testifying under pseudonyms. We wanted to know that so that we understand how to approach that issue in our opening statement. THE COURT: I think we have a pending proposal, with the two sides having slightly different views as to what language to use for those instructions. I haven't dealt with that yet, but I will. And then I guess the second question you're asking is, will I include that in my preliminary instructions as opposed to at the time the first witness is called. It should come before opening, I presume, because you'll refer to witnesses pursuant to pseudonyms during SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00011628",
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- "content": "because of the obvious issue that would arise with attorney-client privilege and with Minor Victim 4's right to representation of counsel. MR. PAGLIUCA: Well, first, your Honor, I don't think that it's appropriate for me to have to discuss defense strategy in this context. However -- THE COURT: That's fine. There will be no -- without briefing, you will not call an attorney for a witness, period. I'm happy to see briefing, but until that happens, you won't. MR. PAGLIUCA: That's fine, your Honor. THE COURT: OK. MS. COMEY: Thank you, your Honor. We had one other question for your Honor, which is whether the Court intends to, in its preliminary instruction, inform the jury that certain witnesses will be testifying under pseudonyms. We wanted to know that so that we understand how to approach that issue in our opening statement. THE COURT: I think we have a pending proposal, with the two sides having slightly different views as to what language to use for those instructions. I haven't dealt with that yet, but I will. And then I guess the second question you're asking is, will I include that in my preliminary instructions as opposed to at the time the first witness is called. It should come before opening, I presume, because you'll refer to witnesses pursuant to pseudonyms during",
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