DOJ-OGR-00018760.pdf

--- Page 1 --- **Document Header:** * **Case Number:** 1:20-cr-00330-PAE * **Document Number:** 753 * **Filed Date:** 08/10/22 * **Page Number:** 162 of 264 * **Page Count:** 1588 **Transcript Text:** 1. talk about it now. 2. MR. PAGLIUCA: Sure. I don't know if you want to deal with Ms. Sternheim's issue first. 3. with Ms. Sternheim's issue first. 4. MS. STERNHEIM: Mine should go to the back of the bus on this. 5. THE COURT: Okay. 6. MR. PAGLIUCA: So there was direct examination testimony, your Honor, concerning psychiatric issues, ongoing psychiatric issues, with this witness. I think there was some minimization of the ongoing psychiatric issues. And the records that I have reflect much more extensive psychiatric issues. 7. I believe that I should be allowed to inquire about her extensive psychiatric history. There were questions on direct examination about her ongoing drug abuse, and I think that opens -- and I think it was minimized. And I think that that opens the door to my being able to examine on the full extent of her ongoing drug abuse. 8. There was also testimony raised sort of in the vein of, I'm schizophrenic and I am schizophrenic about my children because they're important to me, essentially, and that's why I have this schizophrenia and hear voices around my children. This witness has a significant history of having her children taken away from her and these children living with her mother or other relatives. And I think that the way that the 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. **Footer:** * **Southern District Reporters, P.C.** * **Phone Number:** (212) 805-0300 * **Case Number:** DOJ-OGR-00018760 **Additional Text:** * **Case Number:** 1:20-cr-00330-PAE * **Document Number:** 753 * **Filed Date:** 08/10/22 * **Page Number:** 162 of 264 * **Page Count:** 1588 Note: The extracted text includes all visible characters, including numbers, dates, and characters. The formatting and structure of the original document have been preserved as much as possible. Any handwritten notes or unclear text have been included in brackets.