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    "page_number": "24",
    "document_number": "549-1",
    "date": "12/17/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 549-1 Filed 12/17/21 Page 24 of 24 36 LB15MAX2\n1 MS. MENNINGER: No, your Honor. I think it depends on\n2 the trial testimony.\n3 THE COURT: Ms. Moe?\n4 MS. MOE: No, your Honor. Thank you.\n5 THE COURT: It sounds like the government does need to\n6 think about its opening and whether reference to non-testifying\n7 alleged victims would open the door, potentially, to the issue.\n8 MS. MOE: Yes, your Honor. And it remains the\n9 government's position that, to the extent the defense is\n10 offering anything along these lines, it would be for the truth\n11 and, therefore, hearsay. But given the fact that the parties\n12 don't intend to open on this issue, we don't believe our\n13 opening statements would open the door to this issue either, we\n14 are happy to raise this issue at the appropriate time.\n15 THE COURT: OK.\n16 MS. MOE: Thank you, your Honor.\n17 THE COURT: OK. Thank you.\n18 Next is government 8 which are prior statements of\n19 Ms. Maxwell. I think I come away from the papers agreeing with\n20 the defense that this one may be premature but, Ms. Moe, what\n21 is the specific concern? What are prior statements that you\n22 are worried about here?\n23 MS. MOE: Yes, your Honor.\n24 For example, the government has produced to the\n25 defense in discovery a large volume of electronically-stored\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00008418",
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      "content": "1 MS. MENNINGER: No, your Honor. I think it depends on\n2 the trial testimony.\n3 THE COURT: Ms. Moe?\n4 MS. MOE: No, your Honor. Thank you.\n5 THE COURT: It sounds like the government does need to\n6 think about its opening and whether reference to non-testifying\n7 alleged victims would open the door, potentially, to the issue.\n8 MS. MOE: Yes, your Honor. And it remains the\n9 government's position that, to the extent the defense is\n10 offering anything along these lines, it would be for the truth\n11 and, therefore, hearsay. But given the fact that the parties\n12 don't intend to open on this issue, we don't believe our\n13 opening statements would open the door to this issue either, we\n14 are happy to raise this issue at the appropriate time.\n15 THE COURT: OK.\n16 MS. MOE: Thank you, your Honor.\n17 THE COURT: OK. Thank you.\n18 Next is government 8 which are prior statements of\n19 Ms. Maxwell. I think I come away from the papers agreeing with\n20 the defense that this one may be premature but, Ms. Moe, what\n21 is the specific concern? What are prior statements that you\n22 are worried about here?\n23 MS. MOE: Yes, your Honor.\n24 For example, the government has produced to the\n25 defense in discovery a large volume of electronically-stored",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00008418",
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  "entities": {
    "people": [
      "Ms. Menninger",
      "Ms. Moe",
      "Ms. Maxwell"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/17/21"
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      "1:20-cr-00330-PAE",
      "549-1",
      "DOJ-OGR-00008418"
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}