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- "full_text": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 157 of 264 568 LC1VMAX5 Jane - cross 1 it would -- it might have some impact -- my participating would have some impact on the civil litigation, do you have additional questions? 4 MS. MENNINGER: May I confer, your Honor? 5 THE COURT: Yes. 6 (Counsel conferred) 7 MS. MENNINGER: Your Honor, I suppose that there might be additional question -- you know that your lawyer told the government that. 10 THE COURT: So however she answers that, I suppose you want to ask, Do you know that your lawyer told the government that? 13 MS. MENNINGER: Yes. 14 THE COURT: Do you have an objection to the \"Do you know that your lawyer told the government that\"? 16 MS. MOE: I'm sorry, your Honor. I'm trying to follow the logic of trying to impeach a witness by her knowledge of an attorney's statement to the government about a client's intention. I don't think that tracks the logic of impeachment by bias or by a prior inconsistent statement. I'm not sure how that establishes impeachment under the rule. 22 THE COURT: The fact that she knows her lawyer told the government that. 24 MS. MOE: Your Honor, that appears to be an end-run around getting in her conversations with her attorney. Because 25 SOUTERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00012177",
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- "content": "1 it would -- it might have some impact -- my participating would have some impact on the civil litigation, do you have additional questions? 4 MS. MENNINGER: May I confer, your Honor? 5 THE COURT: Yes. 6 (Counsel conferred) 7 MS. MENNINGER: Your Honor, I suppose that there might be additional question -- you know that your lawyer told the government that. 10 THE COURT: So however she answers that, I suppose you want to ask, Do you know that your lawyer told the government that? 13 MS. MENNINGER: Yes. 14 THE COURT: Do you have an objection to the \"Do you know that your lawyer told the government that\"? 16 MS. MOE: I'm sorry, your Honor. I'm trying to follow the logic of trying to impeach a witness by her knowledge of an attorney's statement to the government about a client's intention. I don't think that tracks the logic of impeachment by bias or by a prior inconsistent statement. I'm not sure how that establishes impeachment under the rule. 22 THE COURT: The fact that she knows her lawyer told the government that. 24 MS. MOE: Your Honor, that appears to be an end-run around getting in her conversations with her attorney. Because",
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- "08/10/22"
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