{
  "document_metadata": {
    "page_number": "21",
    "document_number": "212-2",
    "date": "04/16/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 21 of 30\nApp.-0824\nG4LMGIUC 20\n1 The plaintiff has told me that they have now supplied\n2 all the education and employment records that they have. I\n3 think if there is any question about that, if the defense is\n4 skeptical, I would ask the counsel for the plaintiffs to make\n5 that statement on the record, not necessarily here, but by way\n6 of a statement to the Court and principally to the defendant.\n7 On the question of residences, that's, in my view, not\n8 a contention interrogatory because of the nature of this case.\n9 I think it's more like listing witnesses. So I would say that\n10 the plaintiff should supply all residences.\n11 The Dershowitz deposition will be produced under the\n12 confidentiality provision. As I read what I've been given,\n13 it's to be held in confidence and it will remain in confidence,\n14 but it will be produced.\n15 Yes, the tax returns should be produced. 15 years\n16 seems like -- I see. Ok. 15 years\n17 The medical records of the period '99 to 2002 will be\n18 produced and the plaintiff will indicate whether that\n19 production is complete or, if it isn't complete, when it will\n20 be complete.\n21 As for the pre-'99 medical records, based on where we\n22 are at the moment, I do not believe that those are relevant.\n23 Because the damage issue relates, in my view, solely to the\n24 defamation. If that changes in any way, I will revisit that\n25 issue.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00003823",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 21 of 30",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "App.-0824",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "G4LMGIUC 20\n1 The plaintiff has told me that they have now supplied\n2 all the education and employment records that they have. I\n3 think if there is any question about that, if the defense is\n4 skeptical, I would ask the counsel for the plaintiffs to make\n5 that statement on the record, not necessarily here, but by way\n6 of a statement to the Court and principally to the defendant.\n7 On the question of residences, that's, in my view, not\n8 a contention interrogatory because of the nature of this case.\n9 I think it's more like listing witnesses. So I would say that\n10 the plaintiff should supply all residences.\n11 The Dershowitz deposition will be produced under the\n12 confidentiality provision. As I read what I've been given,\n13 it's to be held in confidence and it will remain in confidence,\n14 but it will be produced.\n15 Yes, the tax returns should be produced. 15 years\n16 seems like -- I see. Ok. 15 years\n17 The medical records of the period '99 to 2002 will be\n18 produced and the plaintiff will indicate whether that\n19 production is complete or, if it isn't complete, when it will\n20 be complete.\n21 As for the pre-'99 medical records, based on where we\n22 are at the moment, I do not believe that those are relevant.\n23 Because the damage issue relates, in my view, solely to the\n24 defamation. If that changes in any way, I will revisit that\n25 issue.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003823",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Dershowitz"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "04/16/21",
      "'99",
      "2002"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "212-2",
      "DOJ-OGR-00003823"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or deposition. The text is clear and legible, with no visible redactions or damage."
}