NEW YORK, NEW YORK - MARCH 13: Former Donald Trump lawyer and loyalist Michael Cohen walks out of a Manhattan courthouse after testifying before a grand jury on March 13, 2023 in New York City. The grand jury is investigating payments Cohen arranged and made on behalf of the former president. (Photo by Spencer Platt/Getty Images)

NEW YORK, NEW YORK – MARCH 13: Former Donald Trump lawyer and loyalist Michael Cohen walks out of a Manhattan courthouse after testifying before a grand jury on March 13, 2023 in New York City. The grand jury is investigating payments Cohen arranged and made on behalf of the former president. (Photo by Spencer Platt/Getty Images)

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