DOJ-OGR-00017603.jpg

be NO Case 1:20-cr-00330-PAE LBUCmax7 father-like god family. Document 743 figure when sh Filed 08/10/22 Page 241 of 247 400 e was growing up who helped the 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 during these conversations th that she had to do things tha included massag that there was a woman describing that a woma eS is also an anticipate that Mat LG at the money was will testify tha t she didn't wan t Jane told him ticipate that Ma not for free, t to do, that that tt would testify in the room and he recalls Jane nheim. would make her and oth comfortable while it happened. THE COURT: Ms. Ster MS. STERNHEIM: Your premature since am mindf ul et yet. but witness, cross examinati right now. MS. MO on. tT. ey Your Honor, [ think Honor, er girls who were in the room I don't understand what they're asking n was present while this happened who feel it's somewhat the cross examination has not been concluded the purpose why they're calling this [ think we have to wait to see what happens in for defense counsel put this issue in their opening statement by challenging Jane's credibility and her memory in particular. record both prongs of the rule. So the for a prior consistent statement With respect to the at recently in fabricated it or acted first prong of 801 (d) (1) ( foundation is in the to be admitted under it is B), fluence or motive in so testifying. SOUTH ERN D STR CT REPORT (212 ) 805-0300 ERS, Ps fered to rebut an express or implied charge the declarant from a recent improper DOJ-OGR-00017603