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leading, they could both be exact opposite questions. The witnesses would say the Fifth to everything, and then you look at the jury and you say, okay, now you can impose an adverse inference against anybody you want to based on the questions that the lawyers asked. I mean, that's really what this ends up being, and it's a waste of time, and it is of no evidentiary significance.

Then the last point, which I'm just going to need to

correct Mr. Cassell on, the plaintiffs were saying somehow that

we were untimely in not designating portions of these

depositions which we believe are wholly inadmissible, and the

point of our reply was, wait a minute, you didn't designate any

of this testimony until after the designation date was over.

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SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

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