{
  "document_metadata": {
    "page_number": "160",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 160 of 239\n\nThe defendant, therefore, argues that the questioner asked whether a logically impossible event occurred or will occur at some point over the course of a millennium. But the defendant's professed confusion—which again was not raised during the deposition itself—ignores the plain and obvious context of the question, which did not refer to a time period far exceeding the human life span, and was not limited to only the times in which the defendant was in the act of having sex with Epstein. Plainly, a jury could find that the defendant correctly understood the question when she answered it in July 2016, and that she ascribed a natural meaning to the words used in the questions, and not the tortured illogical meaning she now assigns to those questions: whether, during the course of her relationship with Epstein, she was aware of anyone other than herself having sexual relations with Epstein. The Government expects its evidence to show that she was. See, e.g., Indictment ¶ 1 (stating that the defendant “assisted, facilitated, and contributed to” Epstein's sexual abuse of minors). At a minimum, the defendant's answers were not “literally true under any conceivable interpretation of the questions.” Lighte, 782 F.2d at 374. And the defendant's professed confusion now and proposed illogical reading of the questions in the instant motion does not render them fundamentally ambiguous. See Bonacorsa, 528 F.2d at 1221 (“A defense to a charge of perjury may not be established by isolating a statement from context, giving it in this manner a meaning entirely different from that which it has when the testimony is considered as a whole.”). Accordingly, a jury should be permitted to determine what meaning the defendant ascribed to those questions and whether her answers were in fact false.\n\nFinally, the defendant answered the following questions:\n\nQ. Did you ever give a massage to anyone other than Mr. Epstein at any of Mr. Epstein's properties?\n\nA. First of all, I never said I gave Mr. Epstein a massage.\n\n133\nDOJ-OGR-00003094",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 160 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The defendant, therefore, argues that the questioner asked whether a logically impossible event occurred or will occur at some point over the course of a millennium. But the defendant's professed confusion—which again was not raised during the deposition itself—ignores the plain and obvious context of the question, which did not refer to a time period far exceeding the human life span, and was not limited to only the times in which the defendant was in the act of having sex with Epstein. Plainly, a jury could find that the defendant correctly understood the question when she answered it in July 2016, and that she ascribed a natural meaning to the words used in the questions, and not the tortured illogical meaning she now assigns to those questions: whether, during the course of her relationship with Epstein, she was aware of anyone other than herself having sexual relations with Epstein. The Government expects its evidence to show that she was. See, e.g., Indictment ¶ 1 (stating that the defendant “assisted, facilitated, and contributed to” Epstein's sexual abuse of minors). At a minimum, the defendant's answers were not “literally true under any conceivable interpretation of the questions.” Lighte, 782 F.2d at 374. And the defendant's professed confusion now and proposed illogical reading of the questions in the instant motion does not render them fundamentally ambiguous. See Bonacorsa, 528 F.2d at 1221 (“A defense to a charge of perjury may not be established by isolating a statement from context, giving it in this manner a meaning entirely different from that which it has when the testimony is considered as a whole.”). Accordingly, a jury should be permitted to determine what meaning the defendant ascribed to those questions and whether her answers were in fact false.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "Finally, the defendant answered the following questions:\n\nQ. Did you ever give a massage to anyone other than Mr. Epstein at any of Mr. Epstein's properties?\n\nA. First of all, I never said I gave Mr. Epstein a massage.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "133",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003094",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "July 2016",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "Page 160 of 239",
      "Indictment ¶ 1",
      "Lighte, 782 F.2d at 374",
      "Bonacorsa, 528 F.2d at 1221",
      "DOJ-OGR-00003094"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Jeffrey Epstein. The text discusses the defendant's testimony and potential perjury charges. The document is well-formatted and free of significant damage or redactions."
}