DOJ-OGR-00017566.jpg
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Case 1:20-cr-00330-PAE
LBUCmax5
Document 743
Jane - direct
offered for the truth,
listener. [ would give
the witness's testimony
i
t's being offere
Filed 08/10/22
Page 204 of 247
332
d
the jury a limit
For the ef
fect on
the
ing instruc
tion tha
regarding what h
er mother said is n
fered
being of
For the truth of
impact or ef
limited, Ms.
out-of-court witness,
And then tell me,
down the road
MS.
Moe,
was SO
as to eliciting statements
those statemen
Fect that it had on the witness.
Ls,
We'll keep it
but with
Ms.
I have it
MENN
NG
BR: Your H
with that limiting instruction,
that caveat.
Menninger,
in my head.
onor, if
[ think
issues with other statements by
THE
MS.
order to streamline things becaus
expect th
COURT:
MOE:
xt £
Thank you,
Okay.
y
the mom
our Honor.
'r
n
disclosure.
In part
icular,
Ww
on the subject,
w guestions to be about the issue of
but for th
for an
what your concern
you're admitting it
we'll take up the
when they come up.
ot
e
Just to preview in
[ expect to ask the witness whether
there was ever a time when she talked to a guidance counselor
when she was a kid and whether she cam
mother had found out that she talked to
and I want to talk to her about how her
and told her that she should never talk
their house.
We'r
e offer
ing that, a
anything,
it's certainly not ou
to learn that her
the guidance counselor,
gain, not for
yr position that
SOUTH
ERN D
STR
C
I REPORT
(212)
805-0300
ERS, Ps
the truth of
mother reacted to that
about what goes on in
t she shouldn't
DOJ-OGR-00017566