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    "page_number": "19",
    "document_number": "212-2",
    "date": "04/16/21",
    "document_type": "court transcript",
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  "full_text": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 19 of 30\nApp.-0822\nG4LMGIUC\n18\n1 MS. McCAWLEY: I think we are on the same page.\n2 THE COURT: I think talking about the earlier period.\n3 MS. McCAWLEY: Prior to Epstein, no, no, she doesn't\n4 have a claim with respect to that.\n5 THE COURT: Anything else?\n6 MS. McCAWLEY: Your Honor, I just want to point out\n7 again that our production -- you asked us to complete that. We\n8 have gone through and run over 200 search terms. We have\n9 produced all of those communications she has had with all of\n10 those individuals. The things that we have not produced are\n11 the criminal investigation records. I know your Honor is going\n12 to address that. I would like to be very clear there.\n13 The point there is that she has said in the motion to\n14 stay papers that she filed Tuesday that she needs to have that\n15 information so she can decide whether she is going to be\n16 asserting her Fifth Amendment privilege. Truthful testimony\n17 shouldn't have to be crafted, your Honor. She shouldn't need\n18 to know what agency is investigating her in order to decide\n19 whether or not she is going to be asserting her Fifth Amendment\n20 privilege.\n21 We do have with us, your Honor, for an in camera\n22 submission, if you would like it. That is the way that courts\n23 have dealt with this issue in the past. When there is a claim\n24 from an agency that the disclosure of that investigation could\n25 harm the investigation, we can submit that to you for in camera\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00003821",
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      "content": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 19 of 30",
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      "content": "App.-0822",
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      "content": "G4LMGIUC\n18\n1 MS. McCAWLEY: I think we are on the same page.\n2 THE COURT: I think talking about the earlier period.\n3 MS. McCAWLEY: Prior to Epstein, no, no, she doesn't\n4 have a claim with respect to that.\n5 THE COURT: Anything else?\n6 MS. McCAWLEY: Your Honor, I just want to point out\n7 again that our production -- you asked us to complete that. We\n8 have gone through and run over 200 search terms. We have\n9 produced all of those communications she has had with all of\n10 those individuals. The things that we have not produced are\n11 the criminal investigation records. I know your Honor is going\n12 to address that. I would like to be very clear there.\n13 The point there is that she has said in the motion to\n14 stay papers that she filed Tuesday that she needs to have that\n15 information so she can decide whether she is going to be\n16 asserting her Fifth Amendment privilege. Truthful testimony\n17 shouldn't have to be crafted, your Honor. She shouldn't need\n18 to know what agency is investigating her in order to decide\n19 whether or not she is going to be asserting her Fifth Amendment\n20 privilege.\n21 We do have with us, your Honor, for an in camera\n22 submission, if you would like it. That is the way that courts\n23 have dealt with this issue in the past. When there is a claim\n24 from an agency that the disclosure of that investigation could\n25 harm the investigation, we can submit that to you for in camera",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "type": "printed",
      "content": "DOJ-OGR-00003821",
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  "entities": {
    "people": [
      "McCAWLEY"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "04/16/21",
      "Tuesday"
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      "1:20-cr-00330-PAE",
      "212-2",
      "App.-0822",
      "DOJ-OGR-00003821"
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}