DOJ-OGR-00007103.json 3.9 KB

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  4. "document_number": "465",
  5. "date": "11/15/21",
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  10. "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 52 of 127 52 LB15MAX2\nafter what's alleged in the indictment as of the date of the conspiracy.\nLet me ask, Ms. Moe, if are you in position to say, does the government intend to seek admission of alleged co-conspirator statements that post-date the dates of the conspiracy alleged in the indictment?\nMS. MOE: Your Honor, I think I would want a moment to confer with my colleagues about that and so, if possible, we would like to address that in our November 10th letter.\nIn brief, as a preview, I think to the extent there were any statements that post-dated the time frame of the charged conspiracy we would be offering them only to the extent they reference the charged conduct. But, again, I would like to confer with my colleagues and think through that in detail before making a representation to the Court, and so we ask to brief that as well at the same time.\nTHE COURT: Anyone want to take this now? Or just wait?\nMR. PAGLIUCA: Your Honor, I am happy to wait but it is clear to me that there are post-alleged-conspiracy statements that the government will attempt to introduce and I think we attach what were the representative samples of those statements. And so I don't think it should be a surprise, as we sit here today, what those statements may or may not be. I think whether or not you want to say that those statements go\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007103",
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  14. "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 52 of 127 52 LB15MAX2",
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  19. "content": "after what's alleged in the indictment as of the date of the conspiracy.\nLet me ask, Ms. Moe, if are you in position to say, does the government intend to seek admission of alleged co-conspirator statements that post-date the dates of the conspiracy alleged in the indictment?\nMS. MOE: Your Honor, I think I would want a moment to confer with my colleagues about that and so, if possible, we would like to address that in our November 10th letter.\nIn brief, as a preview, I think to the extent there were any statements that post-dated the time frame of the charged conspiracy we would be offering them only to the extent they reference the charged conduct. But, again, I would like to confer with my colleagues and think through that in detail before making a representation to the Court, and so we ask to brief that as well at the same time.\nTHE COURT: Anyone want to take this now? Or just wait?\nMR. PAGLIUCA: Your Honor, I am happy to wait but it is clear to me that there are post-alleged-conspiracy statements that the government will attempt to introduce and I think we attach what were the representative samples of those statements. And so I don't think it should be a surprise, as we sit here today, what those statements may or may not be. I think whether or not you want to say that those statements go",
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  35. "Ms. Moe",
  36. "MR. PAGLIUCA"
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  39. "SOUTHERN DISTRICT REPORTERS, P.C."
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  42. "dates": [
  43. "11/15/21",
  44. "November 10th"
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  48. "Document 465",
  49. "DOJ-OGR-00007103"
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