mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00012016.json

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  "full_text": "Case 1:20-cr-00330-PAE Document 743 Filed 08/10/22 Page 244 of 247 403 LBUCmax7\n1 each of the witnesses in issue such that the rule would allow prior consistent statements? I suppose the question is whether\na particular statement being offered is consistent with the testimony, but I don't know that it has to be with respect to cross. It seems to me it has to be with respect to direct,\nbecause you asked the jury essentially to evaluate all of the witnesses' testimony as being motivated by memory issues,\nmanipulation, and monetary motivations.\nSo I think that's the issue. I'll certainly think about that question and then consider the -- I think this is a useful example. I'm happy to hear -- I mean, it strikes me that's right, but I'm happy to hear why that wouldn't be right.\nMS. STERNHEIM: I'm not suggesting, I'm just asking for an opportunity to dovetail her testimony with the statement that is the support for the next witness's testimony. I'm not seeking to preclude, I'm just asking for an opportunity on the issue of prior consistency.\nTHE COURT: We can pick this up in the morning, but the government made a specific proffer of anticipated testimony based on direct testimony, which is to say -- I mean, when the witness is testifying, you could say that's not consistent with the prior testimony. Is that what you want to do?\nMS. STERNHEIM: I'm just asking for an opportunity to compare it. I am not standing here saying I'm opposing it.\nTHE COURT: I got it. So it's not about the cross of\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00012016",
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      "content": "1 each of the witnesses in issue such that the rule would allow prior consistent statements? I suppose the question is whether\na particular statement being offered is consistent with the testimony, but I don't know that it has to be with respect to cross. It seems to me it has to be with respect to direct,\nbecause you asked the jury essentially to evaluate all of the witnesses' testimony as being motivated by memory issues,\nmanipulation, and monetary motivations.\nSo I think that's the issue. I'll certainly think about that question and then consider the -- I think this is a useful example. I'm happy to hear -- I mean, it strikes me that's right, but I'm happy to hear why that wouldn't be right.\nMS. STERNHEIM: I'm not suggesting, I'm just asking for an opportunity to dovetail her testimony with the statement that is the support for the next witness's testimony. I'm not seeking to preclude, I'm just asking for an opportunity on the issue of prior consistency.\nTHE COURT: We can pick this up in the morning, but the government made a specific proffer of anticipated testimony based on direct testimony, which is to say -- I mean, when the witness is testifying, you could say that's not consistent with the prior testimony. Is that what you want to do?\nMS. STERNHEIM: I'm just asking for an opportunity to compare it. I am not standing here saying I'm opposing it.\nTHE COURT: I got it. So it's not about the cross of",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "DOJ-OGR-00012016",
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  "entities": {
    "people": [
      "MS. STERNHEIM"
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      "SOUTHERN DISTRICT REPORTERS, P.C.",
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    "dates": [
      "08/10/22"
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      "1:20-cr-00330-PAE",
      "743",
      "DOJ-OGR-00012016"
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