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- "page_number": "258",
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- "date": "08/10/22",
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- "full_text": "Case 1:20-cr-00330-PAE Document 751 Filed 08/10/22 Page 258 of 261 1419 LC6Cmax7 Meder - direct claim that there is some strategic reason why it's okay, it has deprived us of cross examination, which is already compromised by the rulings repeatedly concerning the victims or accusers having certain rights, and they are coming into tension with the rights of our client to have an aggressive defense put forth. MS. MOE: Your Honor, the defense has not been compromised in any way. I want to unpack the facts here -- THE COURT: Just to be clear, we're talking about exhibit 309. MS. STERNHEIM: I know that. THE COURT: I take each objection as it comes. You make your record. It doesn't help analyze it to just talk about larger issues, which I don't know what you're talking about. So each objection as it comes. I'm looking at 309. Your objection is that by not putting it in when the witness is on the stand, you can't cross examine the witness about the context of the photo. Do I have it right? MS. STERNHEIM: That is correct. MS. MOE: Yes, your Honor. So, as defense counsel knows, we showed this photograph to Kate during an interview in September of this year. She identified that as herself and remembered it. Defense counsel has had that note. If they wanted to ask her about this exhibit, that exhibit has been SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00013009",
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- "content": "claim that there is some strategic reason why it's okay, it has deprived us of cross examination, which is already compromised by the rulings repeatedly concerning the victims or accusers having certain rights, and they are coming into tension with the rights of our client to have an aggressive defense put forth. MS. MOE: Your Honor, the defense has not been compromised in any way. I want to unpack the facts here -- THE COURT: Just to be clear, we're talking about exhibit 309. MS. STERNHEIM: I know that. THE COURT: I take each objection as it comes. You make your record. It doesn't help analyze it to just talk about larger issues, which I don't know what you're talking about. So each objection as it comes. I'm looking at 309. Your objection is that by not putting it in when the witness is on the stand, you can't cross examine the witness about the context of the photo. Do I have it right? MS. STERNHEIM: That is correct. MS. MOE: Yes, your Honor. So, as defense counsel knows, we showed this photograph to Kate during an interview in September of this year. She identified that as herself and remembered it. Defense counsel has had that note. If they wanted to ask her about this exhibit, that exhibit has been",
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