{
  "document_metadata": {
    "page_number": "21 of 43",
    "document_number": "739",
    "date": "08/10/22",
    "document_type": "court transcript",
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  "full_text": "Case 1:20-cr-00330-PAE Document 739 Filed 08/10/22 Page 21 of 43 21 LBNAMAXTps would largely be in rebuttal to a government witness. Mr. Flatley was disclosed by the government for similar purposes to talk about the retrieval of metadata from some of the devices that were seized from Epstein's home. To the extent Mr. Flatley talks about the retrieval of metadata or what that metadata means, Mr. Kelso may then be a rebuttal witness, but we don't know yet from the government's disclosure exactly what documents Mr. Flatley intends to refer to. And so that's why there isn't more information about what Mr. Kelso might or might not say. Frankly, we think it would largely be factual. It may stray into areas about metadata if Mr. Flatley offers opinions along those grounds, and we think that it's not accurate. If that's true, we can provide an updated disclosure, once we've heard Mr. Flatley's testimony. THE COURT: Mr. Rohrbach. MR. ROHRBACH: Your Honor, the exhibits that Mr. Flatley is going to talk about are now marked as government exhibits, and the defense has Mr. Flatley's 3500 information as well as examples the government has pointed to where Mr. Flatley has offered similar testimony in other cases in this district and in the Eastern District. So I think the government has given ample notice about what Mr. Flatley will testify about. But as a more general matter, to the extent that the defense provides supplemental notice at some point about SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00011642",
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      "content": "Case 1:20-cr-00330-PAE Document 739 Filed 08/10/22 Page 21 of 43 21 LBNAMAXTps",
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    {
      "type": "printed",
      "content": "would largely be in rebuttal to a government witness. Mr. Flatley was disclosed by the government for similar purposes to talk about the retrieval of metadata from some of the devices that were seized from Epstein's home. To the extent Mr. Flatley talks about the retrieval of metadata or what that metadata means, Mr. Kelso may then be a rebuttal witness, but we don't know yet from the government's disclosure exactly what documents Mr. Flatley intends to refer to. And so that's why there isn't more information about what Mr. Kelso might or might not say. Frankly, we think it would largely be factual. It may stray into areas about metadata if Mr. Flatley offers opinions along those grounds, and we think that it's not accurate. If that's true, we can provide an updated disclosure, once we've heard Mr. Flatley's testimony.",
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    {
      "type": "printed",
      "content": "THE COURT: Mr. Rohrbach.",
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    {
      "type": "printed",
      "content": "MR. ROHRBACH: Your Honor, the exhibits that Mr. Flatley is going to talk about are now marked as government exhibits, and the defense has Mr. Flatley's 3500 information as well as examples the government has pointed to where Mr. Flatley has offered similar testimony in other cases in this district and in the Eastern District. So I think the government has given ample notice about what Mr. Flatley will testify about.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "But as a more general matter, to the extent that the defense provides supplemental notice at some point about",
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011642",
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  "entities": {
    "people": [
      "Mr. Flatley",
      "Mr. Kelso",
      "Mr. Rohrbach",
      "Epstein"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "Eastern District"
    ],
    "dates": [
      "08/10/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "739",
      "DOJ-OGR-00011642"
    ]
  },
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}