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“It is improper for a prosecutor to ask questions that are calculated to elicit or insinuate an inadmissible and highly prejudicial answer.” (quotation omitted) (holding the prosecutor committed misconduct when asking a question that elicited evidence when there was an understanding that said evidence would not be placed at issue); (holding that a prosecutor committed miscondu

witness safety, or interrogation that is repetitive or only marginally relevant.” (quotation omitted).

Svoboda, d at 775; (stating that proponent of evidence had not established relevance “either by extrinsic evidence or by offer of proof”); (noting that “[a]n offer of proof provides an evidentiary basis” for a district court’s evidentiary ruling); Minn. R. Evid.

State v. Brown , (affirming limitation of cross- examination because th e proponent of the evidence made no offer of proof establishing relevancy).

Re-recordings of videotapes “should be accepted as duplicates when shown to have been made by a technique designed to ensure accurate reproduction of the original.”

“The e ssence of confrontation is the opportunity to cross-exam ine opposing witnesses.” State v. Greer , see also State v. Brown , (“[T]he defendant’s right to cross-examine witne sses for bias is secured by the Sixth Amendment.”).

9 Lanz-Terry, at 640-41 (citation omitted) (affirming district court’s decision to limit cross - examination and exclude extrinsic evidence ); see also, d 592, 598-99 (Minn. 2010) (affirming district court’s decision to exclude extrinsic evidence because that evidence was too attenuated to support an argument of bias); (affirming district court ’s decision to disallow bia s- related cross-examination regarding whether one witness was in the same gang as a different witness and quoting Delaware v

“In criminal cases, the defendant’s right to cross-examine witnesses for bias is secured by the Sixth Amendment.”

“It is improper for a prosecutor to ask questions that are calculated to elicit or insinuate an inadmissible and highly prejudicial answer.” (quotation omitted).

2.02 (requiring that all parties and witnesses be treated with respect); (noting that district courts may limit cross-examination when it is harassing, prejudicial, confusing, repetitive, or only marginally relevant (citing Delaware v. Van Arsdall, 475 U.S. 673, 679 , 106 S.Ct.

In State v. Brown, the supreme court stated that when a videotape is duplicated and digitized, “there is the risk of manipulation or distortion.”

(“Inquiry on cross- examination into common gang membership may be sufficiently probative to show bias .

“In criminal cases, the defendant’s right to cross-examine witnesses for bias is secured by 5 the Sixth Amendment.”

“Re-recordings of audio tapes or videotapes should be accepted as duplicates when shown to have been made by a technique designed to ensure accurate reproduction of the original.” (quotation omitted).

See State v. [Trevor] Brown, (outlining relevance and foundational limitations on cross-examination of state’s witnesses about common gang membership).