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Case 1:20-cr-00330-PAE Document 739 Filed 08/10/22 Page14of43 14 LBNAMAXTps 1 displaying -- we don't have to be approaching the witness and 2 we can move seamlessly through this. 3 These are all documents that are in the government' 4 possession to begin with, your Honor. These are not things 5 that are unknown at this point. 6 THE COURT: Again, that seems off topic. But -- so 7 it's manageable to give the government paper. 8 MR. PAGLIUCA: It should be. 9 THE COURT: Any reason you can't -- how about this. 10 Prepare it as a binder for potential use, even if it's not the 11 full document, but anything that you might use -- that you 12 think you might use. As you know, it's a known quantity. You 13 have it in a binder and you could direct them to turn to it. 14 [f it turns out there's something that you do want to show that 15 you didn't put in the binder, we'll deal with that and you'll 16 be able to show it, either by turning off the counsel screens 17 and showing it on the monitor or we'll hand up paper at that 18 point. 19 MR. PAGLIUCA: I think there is going to be a real 20 problem, your Honor, to do it like that. It just -- 21 THE COURT: Help me understand this as a practical 22 matter. You will have your outline for your cross, and you're 23 going to know enough to tell your paralegal, Put up document 24 number so-and-so, page 7. And that's how your paralegal is 25 going to pull that up and put it on the screen, right? Why SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00011635