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    "page_number": "33",
    "document_number": "465",
    "date": "11/15/21",
    "document_type": "court transcript",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 33 of 127 LB15MAX2 conspiracy and so forth. So it is our position that if they open the door to evidence about anyone other than these four then we would, likewise, be able to talk about the fact that those other individuals were interviewed by the government and said that Ms. Maxwell is not involved, was not there, and was not a part of the activities that they're talking about. None of the cases that the government cited had to do with a co-conspirator. The evidence was just because a defendant did not act in conformity with the charged conduct on a separate occasion, couldn't be set forth by the defense. THE COURT: Do you agree with that principle? MS. MENNINGER: Yes, your Honor. If it is good character evidence, generally I understand the rules of evidence wouldn't apply, but what we have here is a 10-year charged conspiracy with an intent by the government to allude to other individuals. To the extent they try to put on evidence in the form of message pads or other types of evidence that refer to other people, then I think we have the ability to confront that evidence with the fact that Ms. Maxwell was reported by those individuals not to have been involved. THE COURT: Ms. Moe? MS. MOE: Thank you, your Honor. The government agrees that this issue can be deferred until trial unless and until this becomes an issue, provided the defense counsel doesn't intend to open on this issue. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007084",
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      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 33 of 127 LB15MAX2",
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    {
      "type": "printed",
      "content": "conspiracy and so forth. So it is our position that if they open the door to evidence about anyone other than these four then we would, likewise, be able to talk about the fact that those other individuals were interviewed by the government and said that Ms. Maxwell is not involved, was not there, and was not a part of the activities that they're talking about. None of the cases that the government cited had to do with a co-conspirator. The evidence was just because a defendant did not act in conformity with the charged conduct on a separate occasion, couldn't be set forth by the defense.",
      "position": "main content"
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    {
      "type": "printed",
      "content": "THE COURT: Do you agree with that principle? MS. MENNINGER: Yes, your Honor. If it is good character evidence, generally I understand the rules of evidence wouldn't apply, but what we have here is a 10-year charged conspiracy with an intent by the government to allude to other individuals. To the extent they try to put on evidence in the form of message pads or other types of evidence that refer to other people, then I think we have the ability to confront that evidence with the fact that Ms. Maxwell was reported by those individuals not to have been involved.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "THE COURT: Ms. Moe? MS. MOE: Thank you, your Honor. The government agrees that this issue can be deferred until trial unless and until this becomes an issue, provided the defense counsel doesn't intend to open on this issue.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00007084",
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  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Ms. Menninger",
      "Ms. Moe"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "11/15/21"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 465",
      "DOJ-OGR-00007084"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}