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  "document_metadata": {
    "page_number": "79",
    "document_number": "465",
    "date": "11/15/21",
    "document_type": "court transcript",
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  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 79 of 127\nLB1TMAX3\n\n1 So on trafficking, the government would seek to have\n2 this testimony as direct evidence with respect to the\n3 trafficking count, because the individual of legal age in all\n4 relevant jurisdictions was under the age of 18. You're going\n5 to have to spell it out for me.\n6 MS. MOE: Yes, your Honor. If the defense were to\n7 argue that the defendant didn't know that victims with respect\n8 to the trafficking count were under the age of 18 or wouldn't\n9 have done this if they were under 18 or that she did not know\n10 that Epstein had a preference for underage girls or his\n11 sexualized massages were with girls under the age of 18, this\n12 would certainly speak to that issue.\n13 In particular, if the defendant were to argue that she\n14 didn't know that the massages she was arranging were\n15 sexualized, I think the testimony of the victim speaking to\n16 that issue would certainly make that all the more relevant.\n17 THE COURT: Right. Okay. I'm not sure the government\n18 had previously argued this constituted direct evidence of the\n19 trafficking count, is that right?\n20 MS. MOE: Your Honor, I would have to review our\n21 briefing. I believe we said that it was direct evidence of the\n22 charged crimes. I apologize if we were vague about that, but\n23 our view is the entire course of conduct speaks to the\n24 defendant's role and knowledge, and the proof here is mutually\n25 sufficient.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00007130",
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      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 79 of 127",
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      "content": "LB1TMAX3",
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      "content": "1 So on trafficking, the government would seek to have\n2 this testimony as direct evidence with respect to the\n3 trafficking count, because the individual of legal age in all\n4 relevant jurisdictions was under the age of 18. You're going\n5 to have to spell it out for me.\n6 MS. MOE: Yes, your Honor. If the defense were to\n7 argue that the defendant didn't know that victims with respect\n8 to the trafficking count were under the age of 18 or wouldn't\n9 have done this if they were under 18 or that she did not know\n10 that Epstein had a preference for underage girls or his\n11 sexualized massages were with girls under the age of 18, this\n12 would certainly speak to that issue.\n13 In particular, if the defendant were to argue that she\n14 didn't know that the massages she was arranging were\n15 sexualized, I think the testimony of the victim speaking to\n16 that issue would certainly make that all the more relevant.\n17 THE COURT: Right. Okay. I'm not sure the government\n18 had previously argued this constituted direct evidence of the\n19 trafficking count, is that right?\n20 MS. MOE: Your Honor, I would have to review our\n21 briefing. I believe we said that it was direct evidence of the\n22 charged crimes. I apologize if we were vague about that, but\n23 our view is the entire course of conduct speaks to the\n24 defendant's role and knowledge, and the proof here is mutually\n25 sufficient.",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00007130",
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  ],
  "entities": {
    "people": [
      "Epstein"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "11/15/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 465",
      "DOJ-OGR-00007130"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}