{
  "document_metadata": {
    "page_number": "15",
    "document_number": "212-2",
    "date": "04/16/21",
    "document_type": "court transcript",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 15 of 30\nApp.-0818\n\nG4LMGIUC\n14\n1 her claimed prior sexual abuse. She has, again, put in the\n2 press a number of statements regarding that, and I can't\n3 imagine that it is to the extent she claims privacy now, those\n4 might be relevant in our case both on credibility and also\n5 damage issues.\n6     Your Honor, we have asked for a lot of other\n7 interrogatories and documents that go to her damage claims, her\n8 education records, her work history. She has refused to answer\n9 any questions before where she has worked. She has refused to\n10 answer any questions about where she went to school. All of\n11 these are appropriate under the local rule for interrogatories.\n12     Finally, your Honor, we have asked for her contracts\n13 with media. She has refused to disclose those. She has\n14 refused to disclose her tax returns that show all of the\n15 payments that she has received from various media sources.\n16     THE COURT: I take it your view of any funds from the\n17 media would operate to reduce her damages.\n18     MS. MENNINGER: Your Honor, it also shows her motive\n19 and bias in bringing this case. To the extent she has been\n20 paid for her stories to the media, which she has, she has\n21 admitted that she has been paid hundreds of thousands of\n22 dollars for giving these stories to the media.\n23     But to the extent that she is now bringing this\n24 defamation claim, if she is still either planning to receive\n25 more money from the media, she has a motive and bias to make\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00003817",
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      "content": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 15 of 30",
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      "type": "printed",
      "content": "App.-0818",
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      "type": "printed",
      "content": "G4LMGIUC\n14\n1 her claimed prior sexual abuse. She has, again, put in the\n2 press a number of statements regarding that, and I can't\n3 imagine that it is to the extent she claims privacy now, those\n4 might be relevant in our case both on credibility and also\n5 damage issues.\n6     Your Honor, we have asked for a lot of other\n7 interrogatories and documents that go to her damage claims, her\n8 education records, her work history. She has refused to answer\n9 any questions before where she has worked. She has refused to\n10 answer any questions about where she went to school. All of\n11 these are appropriate under the local rule for interrogatories.\n12     Finally, your Honor, we have asked for her contracts\n13 with media. She has refused to disclose those. She has\n14 refused to disclose her tax returns that show all of the\n15 payments that she has received from various media sources.\n16     THE COURT: I take it your view of any funds from the\n17 media would operate to reduce her damages.\n18     MS. MENNINGER: Your Honor, it also shows her motive\n19 and bias in bringing this case. To the extent she has been\n20 paid for her stories to the media, which she has, she has\n21 admitted that she has been paid hundreds of thousands of\n22 dollars for giving these stories to the media.\n23     But to the extent that she is now bringing this\n24 defamation claim, if she is still either planning to receive\n25 more money from the media, she has a motive and bias to make",
      "position": "main"
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003817",
      "position": "footer"
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  "entities": {
    "people": [
      "MS. MENNINGER"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "212-2",
      "DOJ-OGR-00003817",
      "App.-0818"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage to the text."
}