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    "page_number": "75",
    "document_number": "465",
    "date": "11/15/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 75 of 127\nLB1TMAX3\n1 point.\n2 Now one might have all kinds of moral judgments and\n3 concerns, but is there a legal sense in which the government\n4 right now in talking to me is just identify the person, or is\n5 there a legal sense in which you're proffering this individual\n6 as an victim of the crimes charged, setting aside you don't\n7 have an answer yet as to whether they may meet some basis for\n8 restitution should the defendant be convicted.\n9 MS. MOE: Yes, your Honor, I'm using that term both\n10 for identification purposes and because I think, as the\n11 victim's testimony will illustrate, she will describe a course\n12 of unwanted conduct, and the way in which she came to engage in\n13 that conduct is as a direct result of the defendant's behavior\n14 in a way that closely mirrors the way the defendant secured\n15 access for Mr. Epstein to the other minor victims in this case.\n16 THE COURT: That is an argument about consent being\n17 the basis for which -- we have put it aside to 412, but as a\n18 general matter you have argued consent is irrelevant because\n19 the age of consent is the only thing in issue for these\n20 charges, but you're saying the relevance of this individual's\n21 testimony turns on the government establishing nonconsensual\n22 sexual conduct?\n23 MS. MOE: No, your Honor, I'm simply explaining why we\n24 are using that term \"victim,\" because that's the way she\n25 characterizes that experience, and I think that will come\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00007126",
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      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 75 of 127",
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      "content": "LB1TMAX3",
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      "content": "1 point.",
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      "content": "Now one might have all kinds of moral judgments and concerns, but is there a legal sense in which the government right now in talking to me is just identify the person, or is there a legal sense in which you're proffering this individual as an victim of the crimes charged, setting aside you don't have an answer yet as to whether they may meet some basis for restitution should the defendant be convicted.",
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      "content": "MS. MOE: Yes, your Honor, I'm using that term both for identification purposes and because I think, as the victim's testimony will illustrate, she will describe a course of unwanted conduct, and the way in which she came to engage in that conduct is as a direct result of the defendant's behavior in a way that closely mirrors the way the defendant secured access for Mr. Epstein to the other minor victims in this case.",
      "position": "main content"
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      "type": "printed",
      "content": "THE COURT: That is an argument about consent being the basis for which -- we have put it aside to 412, but as a general matter you have argued consent is irrelevant because the age of consent is the only thing in issue for these charges, but you're saying the relevance of this individual's testimony turns on the government establishing nonconsensual sexual conduct?",
      "position": "main content"
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    {
      "type": "printed",
      "content": "MS. MOE: No, your Honor, I'm simply explaining why we are using that term \"victim,\" because that's the way she characterizes that experience, and I think that will come",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00007126",
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  "entities": {
    "people": [
      "MS. MOE",
      "Mr. Epstein"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "11/15/21"
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      "1:20-cr-00330-PAE",
      "Document 465",
      "DOJ-OGR-00007126"
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}