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    "page_number": "21",
    "document_number": "549-1",
    "date": "12/17/21",
    "document_type": "court transcript",
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  "full_text": "Case 1:20-cr-00330-PAE Document 549-1 Filed 12/17/21 Page 21 of 24 33 LB15MAX2\n1 conspiracy and so forth. So it is our position that if they open the door to evidence about anyone other than these four\n2 then we would, likewise, be able to talk about the fact that those other individuals were interviewed by the government and\n3 said that Ms. Maxwell is not involved, was not there, and was not a part of the activities that they're talking about. None\n4 of the cases that the government cited had to do with a co-conspirator. The evidence was just because a defendant did\n5 not act in conformity with the charged conduct on a separate occasion, couldn't be set forth by the defense.\n6 THE COURT: Do you agree with that principle?\n7 MS. MENNINGER: Yes, your Honor. If it is good character evidence, generally I understand the rules of evidence\n8 wouldn't apply, but what we have here is a 10-year charged conspiracy with an intent by the government to allude to other\n9 individuals. To the extent they try to put on evidence in the form of message pads or other types of evidence that refer\n10 to other people, then I think we have the ability to confront that evidence with the fact that Ms. Maxwell was reported\n11 by those individuals not to have been involved.\n12 THE COURT: Ms. Moe?\n13 MS. MOE: Thank you, your Honor. The government agrees that this issue can be deferred until trial unless and until\n14 this becomes an issue, provided the defense counsel doesn't intend to open on this issue.\n15 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n16 DOJ-OGR-00008415",
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      "content": "1 conspiracy and so forth. So it is our position that if they open the door to evidence about anyone other than these four\n2 then we would, likewise, be able to talk about the fact that those other individuals were interviewed by the government and\n3 said that Ms. Maxwell is not involved, was not there, and was not a part of the activities that they're talking about. None\n4 of the cases that the government cited had to do with a co-conspirator. The evidence was just because a defendant did\n5 not act in conformity with the charged conduct on a separate occasion, couldn't be set forth by the defense.\n6 THE COURT: Do you agree with that principle?\n7 MS. MENNINGER: Yes, your Honor. If it is good character evidence, generally I understand the rules of evidence\n8 wouldn't apply, but what we have here is a 10-year charged conspiracy with an intent by the government to allude to other\n9 individuals. To the extent they try to put on evidence in the form of message pads or other types of evidence that refer\n10 to other people, then I think we have the ability to confront that evidence with the fact that Ms. Maxwell was reported\n11 by those individuals not to have been involved.\n12 THE COURT: Ms. Moe?\n13 MS. MOE: Thank you, your Honor. The government agrees that this issue can be deferred until trial unless and until\n14 this becomes an issue, provided the defense counsel doesn't intend to open on this issue.",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
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      "type": "printed",
      "content": "DOJ-OGR-00008415",
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  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Ms. Menninger",
      "Ms. Moe"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/17/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "549-1",
      "DOJ-OGR-00008415"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with clear and legible text. There are no visible redactions or damage."
}