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be NO Ww ws Oo OY ~] oO Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-PAE LCLVMAX5 about about Document 745 ‘Filed 08/10/22 Page 155 of 264 566 Jane —- cross nonprivileged communication, right, between the attorney and the witness's attorney and the government. MS. MOE: Yes, your Honor. That is my note to file a conversation with Mr. Glassman. In our view, my notes a conversation with someone who's not this witness can't exhibit at the trial. There are separate questions about be an her conversat privilege issues. Ms. TH oD 25 Bos) COURT: Menninger asking tions with her attorneys that implicates other You don't have any objection to the witness if this criminal she her participation in is the underlying question? question b she expected to get a higher payout in her civil testi for t Ms. MS. Fied in and cooperated in this criminal we g MENN NG BR: Your Let me just get th Honor, has any awareness of proceeding impacting -- what underlying Menninger. the underlying question is case if she case. That's the ultimate underlying issue. THE COURT: Did she have any basis to believe that by testifying in this criminal case, it would aid the payment she would get in the -- with respect to the fund or the civil case? MS. MENNINGER: Well, they ultimately became as one. But at the time her initial advice from Mr. Glassman came in, there was not a victims' compensation fund. That arose during the course of her civil case. And so -- THE COURT: And the line you're interested in is that SOUTHERN DISTRICT REPORTERS, P.C. (212%) 805-0220 DOJ-OGR-00012175