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- "full_text": "Case 1:20-cr-00330-AJN Document 763 Filed 08/10/22 Page 147 of 197\nLCHVMAX4\n2688\n1\nMS. MENNINGER: Well, at the time, because I was not\n2\nin touch with that witness, I didn't know if we were going to\n3\nmove to have her testify under her first name, given --\n4\nTHE COURT: And did you so move?\n5\nMS. MENNINGER: I did not with respect to this witness\n6\nbecause I hadn't spoken to her. The witnesses that we've\n7\nmoved --\n8\nTHE COURT: Right. But so you've never sought\n9\nanonymity with respect to this witness.\n10\nMS. MENNINGER: That's correct.\n11\nMS. MOE: I also add, your Honor, that when defense\n12\ncounsel wanted to put in the record the first and last names of\n13\nfolks when there were sensitivities, they wrote them down on a\n14\npiece of paper. There were a million different ways to get\n15\nthat before the jury, and they chose not to.\n16\nMS. MENNINGER: I understand that the cross -- or the\n17\ndirect would be based on what the questions were of Jane. I'm\n18\nnot here to dispute that. I'm just telling the Court in terms\n19\nof who it is. She told the government the last name and what\n20\nshe told the government.\n21\nTHE COURT: I understand. Which just indicates that\n22\nthe defense has been on notice of this person, which I presume\n23\nis what -- since October, as someone who Jane indicated was\n24\ninvolved in the sexualized massages. I presume that's why you\n25\nnoticed this person Kelly as a defense witness and issued a\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00016876",
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- "content": "1\nMS. MENNINGER: Well, at the time, because I was not\n2\nin touch with that witness, I didn't know if we were going to\n3\nmove to have her testify under her first name, given --\n4\nTHE COURT: And did you so move?\n5\nMS. MENNINGER: I did not with respect to this witness\n6\nbecause I hadn't spoken to her. The witnesses that we've\n7\nmoved --\n8\nTHE COURT: Right. But so you've never sought\n9\nanonymity with respect to this witness.\n10\nMS. MENNINGER: That's correct.\n11\nMS. MOE: I also add, your Honor, that when defense\n12\ncounsel wanted to put in the record the first and last names of\n13\nfolks when there were sensitivities, they wrote them down on a\n14\npiece of paper. There were a million different ways to get\n15\nthat before the jury, and they chose not to.\n16\nMS. MENNINGER: I understand that the cross -- or the\n17\ndirect would be based on what the questions were of Jane. I'm\n18\nnot here to dispute that. I'm just telling the Court in terms\n19\nof who it is. She told the government the last name and what\n20\nshe told the government.\n21\nTHE COURT: I understand. Which just indicates that\n22\nthe defense has been on notice of this person, which I presume\n23\nis what -- since October, as someone who Jane indicated was\n24\ninvolved in the sexualized massages. I presume that's why you\n25\nnoticed this person Kelly as a defense witness and issued a",
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