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10 11 12 13 Case 1:20-cr-00330-PAE Document562 - Filed 12/17/21 Page 74 of 82 Instruction No. 55: Preparation of Witnesses You have heard evidence during the trial that witnesses have discussed the facts of the case and their testimony with the Government lawyers, the defense lawyers, or their own lawyers before the witnesses appeared in court. Although you may consider that fact when you are evaluating a witness’s credibility, I should tell you that there is nothing either unusual or improper about a witness meeting with lawyers before testifying so that the witness can be aware of the subjects he or she will be questioned about, focus on those subjects, and have the opportunity to review relevant exhibits before being questioned about them. Such consultation helps conserve your time and the Court’s time. In fact, it would be unusual for a lawyer to call a witness without such consultation. Again, the weight you give to the fact or the nature of the witness’s preparation for his or her testimony and what inferences you draw from such preparation are matters completely within your discretion. re DOJ-OGR-00008530