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Case 1:20-cr-00330-AJN Document 741 Filed 08/10/22 Page 57 of 106
LBTVMAX3
Opening —- Ms.
topics to ask the client about.
good-faith basis to suggest to this jury
vidence befor
them at this trial;
61
Sternheim
That certainly couldn't be a
that there will be
that these wer
mor
manipulated by their attorneys who cultivated their specific
stories
your Honor.
told to the government.
We think that's inappropriate,
THE COURT: I'm going to overrule it at the opening
stage. I did not preclude the line of argumentation; I wasn't
asked to preclude the line of argumentation. You raised the
prospect -- you did certainly and I appreciate it, raise the
prospect related to a subpoena of a witness's attorney, which I
agree with the government
is ent
would be able -- but if
existing nonprivileged in
tirely unclear to me how that
fers that it's based on
the prof
Formation
From which the jury could
infer that these attorneys structured in some way the questions
that were asked,
think the Line is
basis to say that the attorneys told
What evidenc
attorneys
MR.
PAGLIUCA:
Honor. Wwe
answers to
include Ms. Maxwell;
have in 2008
interrogatories
one
told the witnesses what to
Well,
T'il
that
deposition
you going
so we back up a little bit,
I don't think you have any
the witnesses what to say.
to put in that shows the
say?
your
use Carolyn as the example —-—
are detailed that do not
testimony that is detailed but
91-page complaint detailed, but
does not include Ms. Maxwell; a
does not include Ms. Maxwell.
SOUTHERN
DISTRICT REPORTERS, P.C.
(212)
805-0300
DOJ-OGR-00016167