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    "page_number": "23",
    "document_number": "20",
    "date": "07/16/19",
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  "full_text": "Case 1:19-cr-00490-RMB Document 20 Filed 07/16/19 Page 23 of 24 23 j782epsC kjc that those victims weren't treated as badly as the parade of horribles he has in mind. But for now the question is whether the defendant's attendance can be assured. And with respect to the nonprosecution agreement -- THE COURT: I'm not sure I would refer to something as only statutory rape. The use of the word \"only\" before \"statutory rape\" I'm not sure sits well. But go ahead. MR. ROSSMILLER: And I agree, your Honor. With respect to the actual substance, the Southern District of Florida has represented in public filings that the nonprosecution agreement was limited to the Southern District of Florida, and we can litigate that in a motion to dismiss, but it is simply not relevant here. With respect to the statute of limitations, Mr. Weingarten says that the conduct is old. He did not say that that it is beyond the statute of limitations because it is not. And, finally, it is not the same conduct. Some of the conduct overlaps. Some of the conduct does not. And in particular, one of the two counts of the indictment is predicated exclusively on New York victims. So for all of those reasons, we just ask the court to consider those responses as it awaits the defendant's filings later this week. MR. WEINGARTEN: Can I just make one point to clarify? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000428",
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      "type": "printed",
      "content": "j782epsC kjc that those victims weren't treated as badly as the parade of horribles he has in mind. But for now the question is whether the defendant's attendance can be assured. And with respect to the nonprosecution agreement -- THE COURT: I'm not sure I would refer to something as only statutory rape. The use of the word \"only\" before \"statutory rape\" I'm not sure sits well. But go ahead. MR. ROSSMILLER: And I agree, your Honor. With respect to the actual substance, the Southern District of Florida has represented in public filings that the nonprosecution agreement was limited to the Southern District of Florida, and we can litigate that in a motion to dismiss, but it is simply not relevant here. With respect to the statute of limitations, Mr. Weingarten says that the conduct is old. He did not say that that it is beyond the statute of limitations because it is not. And, finally, it is not the same conduct. Some of the conduct overlaps. Some of the conduct does not. And in particular, one of the two counts of the indictment is predicated exclusively on New York victims. So for all of those reasons, we just ask the court to consider those responses as it awaits the defendant's filings later this week. MR. WEINGARTEN: Can I just make one point to clarify?",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00000428",
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  "entities": {
    "people": [
      "MR. ROSSMILLER",
      "MR. WEINGARTEN"
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    "organizations": [
      "Southern District of Florida",
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [
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    "dates": [
      "07/16/19"
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      "1:19-cr-00490-RMB",
      "Document 20",
      "DOJ-OGR-00000428"
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