{
  "document_metadata": {
    "page_number": "25",
    "document_number": "737",
    "date": "07/22/22",
    "document_type": "court transcript",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 737 Filed 07/22/22 Page 25 of 101\nM6SQmax1\n1 THE COURT: It's not dated November 2004; am I right?\n2 It's on a page that has dates surrounding it of December, November.\n3\n4 MS. MOE: Yes, your Honor, all of the dates surrounding the message would be after November 1, 2004. The neighboring dates are November 13. There's a date in December.\n5\n6 And I think looking at the message pads as a whole, it tells us they're dated essentially sequentially.\n7\n8 THE COURT: Is there any way to tell -- again, this is very technical -- if it's October and November?\n9\n10 MS. MOE: Your Honor, I'd be happy to take a look at physical book. I just have the sheet in front of me to see the page before and after, if the Court would like to examine it.\n11\n12 Our view is the combination of the message itself and the neighboring dates tell us it's November of 2004. In addition, as we noted in our brief, the defendant was still traveling with Epstein during this exact same time period. Again, it's the defendant's burden to establish withdrawal from an ongoing conspiracy, which they've not attempted to do, nor could they.\n13\n14 We think that the message pads, the flight records, the fact that the testimony of a crime victim Carolyn was that the conspiracy was ongoing more than meets this burden.\n15\n16 THE COURT: Okay.\n17\n18 MR. EVERDELL: Your Honor, if I could just respond to that. I do pick up on what the Court is saying, and we agree\n19\n20 SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00011544",
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      "content": "Case 1:20-cr-00330-PAE Document 737 Filed 07/22/22 Page 25 of 101",
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      "type": "printed",
      "content": "M6SQmax1",
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      "type": "printed",
      "content": "1 THE COURT: It's not dated November 2004; am I right?\n2 It's on a page that has dates surrounding it of December, November.\n3\n4 MS. MOE: Yes, your Honor, all of the dates surrounding the message would be after November 1, 2004. The neighboring dates are November 13. There's a date in December.\n5\n6 And I think looking at the message pads as a whole, it tells us they're dated essentially sequentially.\n7\n8 THE COURT: Is there any way to tell -- again, this is very technical -- if it's October and November?\n9\n10 MS. MOE: Your Honor, I'd be happy to take a look at physical book. I just have the sheet in front of me to see the page before and after, if the Court would like to examine it.\n11\n12 Our view is the combination of the message itself and the neighboring dates tell us it's November of 2004. In addition, as we noted in our brief, the defendant was still traveling with Epstein during this exact same time period. Again, it's the defendant's burden to establish withdrawal from an ongoing conspiracy, which they've not attempted to do, nor could they.\n13\n14 We think that the message pads, the flight records, the fact that the testimony of a crime victim Carolyn was that the conspiracy was ongoing more than meets this burden.\n15\n16 THE COURT: Okay.\n17\n18 MR. EVERDELL: Your Honor, if I could just respond to that. I do pick up on what the Court is saying, and we agree",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011544",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "MS. MOE",
      "THE COURT",
      "MR. EVERDELL",
      "Epstein",
      "Carolyn"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "November 2004",
      "November 1, 2004",
      "November 13",
      "December",
      "October",
      "July 22, 2022"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "737",
      "DOJ-OGR-00011544",
      "(212) 805-0300"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}