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576 Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 165 of 264 LC1VMAX5 Jane — cross 1 MS. MOE: Thank you. 2 THE COURT: Ms. Menninger, is that getting at what you 3 are suggesting? 4 MS. MENNINGER: t is. [ believe that he also a communicated that testifying would benefit her in the criminal 6 case. 7 THE COURT: Okay. 8 MS. MENNINGER: And so I'm not privy to whether, you 9 know, at what point in time -- 10 THE COURT: How about did you ever have an 11 understanding that any cooperation with the government, 12 including testifying in this trial, would aid you in any way in 13 your efforts to recover in the then-pending civil litigation? 14 Does that get at it, Ms. Menninger? I'm not disputing that you 15 should ask the question. agree with Ms. Moe there's points 16 for confusion, so let's just -- 17 MS. MENNINGER: think it does, your Honor. 18 I would have to kind of -- I would like to just write 19 out the question so I understand. But do think, as 20 mentioned a little bit earlier, because the civil litigation 21 morphed into the victims' comp fund, there may be a similar 22 question with respect to the comp fund. But think can 23 draft this language and we could -- can tell your Honor what 24 it is in just a minute. 25 THE COURT: Okay. SOUTHERN DISTRICT REPORTERS, P.C. (212%) 805-0220 DOJ-OGR-00012185