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be N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 Case 1:20-cr-00330-PAE LBNAMAXTps MS. attempted to. proper ground for curfew violati COMEY : ons, credibility, and that they will not the deit need a pretrial ruling so that we know whether w those things on direct to draw the st MR. me that this PAGLI UCA: Your Honor, think, to be raised. T government wants to talk about within the rules, and —- THE sounds like they're saying outside of things that are cl COURT: I the rules, early within th he don' Document 536 Your Honor, for cross-examination, Filed 12/10/21 list , laundry list o misdemeanor convictions raise those issues on cross. Page4of43 4 I can assure you we've We raised issues that we thought are clearly not like arrests as a juvenile that are more than ten years old, things that have nothing do with fFense told us that they cannot assure us We obviously have to raise ting. is being raised, but this is a surprising issue, I this is not a surprise to f things that the in their view. mature, agreement can be had. the law, resolve it. When you h reasonable discussion, faith and reasonable and based on include things e rules. t want a speech. that are clearly What it I want, there are things that are clearly And you say there are You'll have a and come to some agreement where ave disputes available that are good you'll submit to me in writing and interpretations of I'll be happy to MR. PAGLIUCA: That's totally fine, your Honor. guess the problem is -- and this is where we're going to end SOUTHERN DISTRICT REPORTERS, oG w (212) 805-0300 DOJ-OGR-00008314