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be NO Ww ws Oo OY ~] oO Ke) a oO he be No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 Case 1:20-cr-00330-PAE LCGVMAX5 Q. About 1,000 A. Well, I don't times? know about 1,000, L Document 761 oftus - cross Filed 08/10/22 Page 160 of 246 2455 but hundreds of times. Q. Okay. And of those hundreds of times, you've consulted with the prosecution about five or six times, right? A. That's approximately the number of times I've been called by prosecutors to consult, yes. Q. I want to talk about your trial testimony. You tes 300 trials, right 95 A. Approximately, yes. trials are criminal ified earlier that you have testified in about trials, right? QO. About half of those A. It's an estimate, but Q. Okay. So you've testi right? A. Approximately, yes. Q. And of the 150 times that you've testit testified for the defens A. Correct. QO. And that one time let's say roughly half, yes. fied in about 150 criminal trials, Fied at trial, you've very single time but once, right? that you didn't testi fy for the defense was in the 1990s, right? A. It was a case in Wisconsin is what I remember. I think it might have been the '90s, yes. Q. So it's fair to say that you've made a career out of being a witness for the defense, right? A. In criminal cases it's predominantly been testimony for the SOUTHERN DISTRICT REPORTERS, P.C. (212%) 805-0220 DOJ-OGR-00016643