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- "full_text": "Case 1:20-cr-00330-PAE Document 536 Filed 12/10/21 Page 10 of 43 10 LBNAMAXTps something, and this witness is technically, I believe, a records custodian. He may be of a higher level than your standard records custodian, but his testimony is sort of ancillary to the charges in this indictment. THE COURT: All right. The purpose of me asking the parties to submit a list of entities or addresses that may be mentioned during trial was to capture this sort of issue. It sounds like the government failed to include a financial institution that will be mentioned during trial. I agree. It's too late to go back and redo that, having failed to do so. So I think if you think it's an issue, it's a peremptory. What else? MS. COMEY: No other issues, your Honor, other than the outstanding ones your Honor outlined. THE COURT: OK. Any -- go ahead. MR. PAGLIUCA: Yes. Your Honor, I wanted to talk a little bit about use of impeachment material during trial. I have a concern -- well, what I am proposing is that if we are going to be either impeaching or refreshing recollection of a particular witness, that we be able to do it electronically. I think that that would be fine, and that's typically how we would do this. The problem with using impeachment material during the course of SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00008320",
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- "content": "something, and this witness is technically, I believe, a records custodian. He may be of a higher level than your standard records custodian, but his testimony is sort of ancillary to the charges in this indictment. THE COURT: All right. The purpose of me asking the parties to submit a list of entities or addresses that may be mentioned during trial was to capture this sort of issue. It sounds like the government failed to include a financial institution that will be mentioned during trial. I agree. It's too late to go back and redo that, having failed to do so. So I think if you think it's an issue, it's a peremptory. What else? MS. COMEY: No other issues, your Honor, other than the outstanding ones your Honor outlined. THE COURT: OK. Any -- go ahead. MR. PAGLIUCA: Yes. Your Honor, I wanted to talk a little bit about use of impeachment material during trial. I have a concern -- well, what I am proposing is that if we are going to be either impeaching or refreshing recollection of a particular witness, that we be able to do it electronically. I think that that would be fine, and that's typically how we would do this. The problem with using impeachment material during the course of",
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