{
  "document_metadata": {
    "page_number": "20 of 23",
    "document_number": "311-1",
    "date": "07/02/21",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": true
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  "full_text": "Case 1:20-cr-00330-PAE Document 311-1 Filed 07/02/21 Page 20 of 23\n\nx j3q1gra\n\nSEALED\n\n1 in order to give whatever in discovery they gave, whether it\n2 was deposition testimony they gave or -- then again, I can't\n3 fathom why anybody who has any criminal exposure would not have\n4 taken the Fifth Amendment in response to questions in a civil\n5 deposition, but I don't know.\n\nMR. ROSSMILLER: So just taking that very briefly in\n6 order, your Honor, I do not know, but I think it is entirely\n7 possible that what we are seeking is page after page of people\n8 taking the Fifth. That is entirely possible. But to the\n9 extent that it is not or there are other materials -- and this\n10 may be bad for our argument, but in all transparency and\n11 candor, I think there may be other individuals who also relied\n12 on the protective order. In other words, anyone other than the\n13 parties who were deposed may have, in theory, and perhaps\n14 unreasonably, relied on it.\n\nTHE COURT: For example, the target of your\n15 investigation.\n\nMR. ROSSMILLER: For example, the target of our\n16 investigation. But I don't think that the parties would be\n17 differently situated in terms of their rights, and there are\n18 certainly many cases that talk about how the government has the\n19 ability to grant immunity in a criminal investigation, but not,\n20 of course, through restricting materials --\n\nTHE COURT: But that's the whole point of the\n21 government needing to follow the procedure, the proper\n22\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300 SDNY_GM_00000871\nDOJ-OGR-00004913",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 311-1 Filed 07/02/21 Page 20 of 23",
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    {
      "type": "printed",
      "content": "x j3q1gra\n\nSEALED",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "1 in order to give whatever in discovery they gave, whether it\n2 was deposition testimony they gave or -- then again, I can't\n3 fathom why anybody who has any criminal exposure would not have\n4 taken the Fifth Amendment in response to questions in a civil\n5 deposition, but I don't know.\n\nMR. ROSSMILLER: So just taking that very briefly in\n6 order, your Honor, I do not know, but I think it is entirely\n7 possible that what we are seeking is page after page of people\n8 taking the Fifth. That is entirely possible. But to the\n9 extent that it is not or there are other materials -- and this\n10 may be bad for our argument, but in all transparency and\n11 candor, I think there may be other individuals who also relied\n12 on the protective order. In other words, anyone other than the\n13 parties who were deposed may have, in theory, and perhaps\n14 unreasonably, relied on it.\n\nTHE COURT: For example, the target of your\n15 investigation.\n\nMR. ROSSMILLER: For example, the target of our\n16 investigation. But I don't think that the parties would be\n17 differently situated in terms of their rights, and there are\n18 certainly many cases that talk about how the government has the\n19 ability to grant immunity in a criminal investigation, but not,\n20 of course, through restricting materials --\n\nTHE COURT: But that's the whole point of the\n21 government needing to follow the procedure, the proper",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300 SDNY_GM_00000871\nDOJ-OGR-00004913",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "MR. ROSSMILLER"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "07/02/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "311-1",
      "SDNY_GM_00000871",
      "DOJ-OGR-00004913"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a 'SEALED' stamp. The content discusses legal proceedings and the Fifth Amendment. The footer contains information about the reporting company and reference numbers."
}