{
  "document_metadata": {
    "page_number": "34",
    "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 34 of 127 34 LB15MAX2\n1 However, even if this became an issue at the trial, the remedy would be to permit the defense to call these relevant witnesses to talk about whether the defendant was or was not involved in their sex trafficking. The remedy would not be to permit defense from cross-examining law enforcement agents about hearsay statements that other individuals provided to them. It would be extremely confusing for the jury to be hearing, through law enforcement agents, the statements of these individuals to assess whether or not those individuals implicated the defendant or simply said nothing about the defendant. And so, the government submits that the only way that this could come in at trial would be if the defense called those witnesses themselves and, of course, it is difficult to determine the potential relevance, if any, of testimony along those lines, and so the government respectfully submits that none of this should be offered at trial unless and until there is an offer of proof along those lines.\nTHE COURT: Ms. Menninger?\nMS. MENNINGER: Your Honor, whether someone said no one else involved or didn't implicate our client is not hearsay, it is the absence of a statement. So I don't understand the government's position that if an investigator --\nTHE COURT: It is not the absence of the statement, right? If you are trying to put in an out-of-court statement from someone who said that Ms. Maxwell wasn't involved, it is\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 34 of 127 34 LB15MAX2",
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    {
      "type": "printed",
      "content": "1 However, even if this became an issue at the trial, the remedy would be to permit the defense to call these relevant witnesses to talk about whether the defendant was or was not involved in their sex trafficking. The remedy would not be to permit defense from cross-examining law enforcement agents about hearsay statements that other individuals provided to them. It would be extremely confusing for the jury to be hearing, through law enforcement agents, the statements of these individuals to assess whether or not those individuals implicated the defendant or simply said nothing about the defendant. And so, the government submits that the only way that this could come in at trial would be if the defense called those witnesses themselves and, of course, it is difficult to determine the potential relevance, if any, of testimony along those lines, and so the government respectfully submits that none of this should be offered at trial unless and until there is an offer of proof along those lines.",
      "position": "main"
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    {
      "type": "printed",
      "content": "THE COURT: Ms. Menninger?",
      "position": "main"
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    {
      "type": "printed",
      "content": "MS. MENNINGER: Your Honor, whether someone said no one else involved or didn't implicate our client is not hearsay, it is the absence of a statement. So I don't understand the government's position that if an investigator --",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "THE COURT: It is not the absence of the statement, right? If you are trying to put in an out-of-court statement from someone who said that Ms. Maxwell wasn't involved, it is",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Ms. Menninger",
      "Ms. Maxwell"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "11/15/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 465"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}