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fe NO Ww ws Oo OY ~] oO Ke) a oO a fe No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 Case 1:20-cr-00330-PAE LBTVMAX3 topics to ask the client about. good-faith basis to suggest to this jury vidence befor manipulated by their attorneys who c stories your Honor. Document 741 Opening —- Ms. them at this trial; told to the government. lude th That cert Filed 08/10/22 line of of Page 57 of 106 61 Sternheim tainly couldn't be a that there will be that thes ultivat We think that argumentation; argumentation. THE COURT: stage. I did not preci asked to preclude the lin prospect -- you did certainly and I prospect related to a subpoena of agree with the government would be able -- but if existing nonprivileged in in that were asked, is ent the prof appreciate it, You raised wer mor ted their specific "s inappropriate, I'm going to overrule it at the opening I wasn't the raise the a witness's attorney, Formation basis to say that the attorneys told think the Line is I don' the wit which I tirely unclear to me how that fers that it's based on From which the jury could fer that these attorneys structured in some way the questions t think you have any tnesses what to say. What evidence are you going to put in that shows the attorneys told the witnesses what to say? MR. PAGLIUCA: Well, so we back up a little bit, your Honor. We have in 2008 -- I'll use Carolyn as the example -- answers to interrogatories that are detailed that do not include Ms. Maxwell; deposition testimony that is detailed but does not include Ms. Maxwell; a 9l-page complaint detailed, but does not include Ms. Maxwell. SOUTHERN DISTRICT REPORTERS, P.C. (212%) 805-0220 DOJ-OGR-00011722