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- "full_text": "Case 1:20-cr-00330-PAE Document 759 Filed 08/10/22 Page 7 of 267 2034 LCACmax1 2000s wasn't even in the United States in the 1990s. In fact, her date of birth and age makes clear that she could not be an adult in the 1990s on that flight -- THE COURT: It's a rebuttal witness. MS. MOE: Yes, your Honor. THE COURT: On the disclosure front, I suppose if they want to make you wait and do it in rebuttal -- why you want to do that, I'm not sure, but on the disclosure front, it's clearly a rebuttal witness. I don't think someone that they could have anticipated needing but for the arguments put forward by the defense, you tell me if I'm wrong, but I'd certainly let -- on the disclosure front, I'd let the government call the person as a rebuttal witness. Whether we do that now or in rebuttal, I suppose, is -- I'll hear from both sides on that question. And then relevance, I think you've indicated the rebuttal relevance of the evidence you're seeking to get in? MS. MOE: Yes, your Honor. On the disclosure front, I want to make clear we produced this exhibit the same day we received it. We were on equal footing with the defense here. In terms of the content of the testimony in the exhibit, it's just a picture and date of birth, which is information the defense has had or for a very long time now. It's a person that the defendant herself knows. So I don't think there is any surprise or mystery SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00013598",
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- "content": "2000s wasn't even in the United States in the 1990s. In fact, her date of birth and age makes clear that she could not be an adult in the 1990s on that flight -- THE COURT: It's a rebuttal witness. MS. MOE: Yes, your Honor. THE COURT: On the disclosure front, I suppose if they want to make you wait and do it in rebuttal -- why you want to do that, I'm not sure, but on the disclosure front, it's clearly a rebuttal witness. I don't think someone that they could have anticipated needing but for the arguments put forward by the defense, you tell me if I'm wrong, but I'd certainly let -- on the disclosure front, I'd let the government call the person as a rebuttal witness. Whether we do that now or in rebuttal, I suppose, is -- I'll hear from both sides on that question. And then relevance, I think you've indicated the rebuttal relevance of the evidence you're seeking to get in? MS. MOE: Yes, your Honor. On the disclosure front, I want to make clear we produced this exhibit the same day we received it. We were on equal footing with the defense here. In terms of the content of the testimony in the exhibit, it's just a picture and date of birth, which is information the defense has had or for a very long time now. It's a person that the defendant herself knows. So I don't think there is any surprise or mystery",
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