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Case 1:20-cr-00330-PAE
LBF3MAXC
understanding that the government wil
victims today
, and will
Document 529
file any --
Filed 12/08/21
Ll provide not
suppose at
Page 14 of 18
14
tice to the
that point you
could phrase it as a motion to quash the subpoena by Wednesday.
Defense response by Friday. Okay.
Yes, Ms. Comey.
MS. COMEY: Yes, your Honor.
bring up
counsel to reach points of
stipulations
certain piece
as t
s of
for your Honor.
o certain
videnc
agreement,
pieces of
where w
believe w
All right.
Two issues we wanted to
We've been working with defense
and have reached
evidence.
brief authent
certain
icat
ion
For your Honor.
birth certii
think we need to brief.
counsel,
like to set a schedule
And
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is
I believe,
areas that we
of government
those, but if
t do
we plan
believe would be improper
witnesses.
we
brief
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authentication issues?
MS.
COME
We have been cont
Okay.
Particularly,
But there are
may need to
there are
I don't think we are going to reach agreement,
for the briefing on that.
fFicates and a prior sworn statement that we
ferring with defense
so we'd
the other issue we wanted to put on your Honor's
need a briefing schedule at this point
to confer with
defense counsel about
reach agreement,
Honor.
So what do you propose
for cross-examination
Usually we can reach agreement on
then we will need to
for the
Y: We would propose that the government
SOUTHERN
DISTR
CT RE
PORT
BRS, Pes
(212)
805-0300
DOJ-OGR- 00008258