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  "document_metadata": {
    "page_number": "28 of 30",
    "document_number": "212-2",
    "date": "04/16/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 28 of 30\nApp.-0831\nG4LMGIUC\n27\n1 Your representation sounds right.\n2 MR. EDWARDS: Additionally, just with respect to the\n3 affidavit, there needs to be an affirmation that we have no\n4 other claims that relate to the statements in this case. Is\n5 that what we are saying?\n6 THE COURT: I think it should be broader than that. I\n7 think it should be -- look. I don't think it would be\n8 appropriate if there is any possibility for either of you to\n9 being a party. That's what I'm after. And having any\n10 proceedings against you arising out of the situation with the\n11 plaintiff. I think it would be inappropriate for you to be\n12 counsel if you have the potentiality of being a party, either\n13 plaintiff or defendant, in any proceedings. If I get an\n14 affidavit saying that you're unaware of any claims against you\n15 or any intention to make a claim arising out of the\n16 circumstances surrounding this lawsuit, that should be broad.\n17 I think that would satisfy me.\n18 MR. EDWARDS: Ok.\n19 MR. CASSELL: I'll be filing those materials this\n20 afternoon, your Honor. My plan is to attend --\n21 THE COURT: The defense has a thought on this.\n22 MR. PAGLIUCA: Your Honor, I am looking at documents\n23 from Florida. One is a docket sheet captioned: Epstein v.\n24 Brad Edwards and Paul G. Cassell, Lower Tribune Cases 15 000072\n25 which shows that that matter is still pending. There is\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00003830",
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      "content": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 28 of 30",
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      "content": "App.-0831",
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    {
      "type": "printed",
      "content": "G4LMGIUC\n27",
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      "type": "printed",
      "content": "1 Your representation sounds right.\n2 MR. EDWARDS: Additionally, just with respect to the\n3 affidavit, there needs to be an affirmation that we have no\n4 other claims that relate to the statements in this case. Is\n5 that what we are saying?\n6 THE COURT: I think it should be broader than that. I\n7 think it should be -- look. I don't think it would be\n8 appropriate if there is any possibility for either of you to\n9 being a party. That's what I'm after. And having any\n10 proceedings against you arising out of the situation with the\n11 plaintiff. I think it would be inappropriate for you to be\n12 counsel if you have the potentiality of being a party, either\n13 plaintiff or defendant, in any proceedings. If I get an\n14 affidavit saying that you're unaware of any claims against you\n15 or any intention to make a claim arising out of the\n16 circumstances surrounding this lawsuit, that should be broad.\n17 I think that would satisfy me.\n18 MR. EDWARDS: Ok.\n19 MR. CASSELL: I'll be filing those materials this\n20 afternoon, your Honor. My plan is to attend --\n21 THE COURT: The defense has a thought on this.\n22 MR. PAGLIUCA: Your Honor, I am looking at documents\n23 from Florida. One is a docket sheet captioned: Epstein v.\n24 Brad Edwards and Paul G. Cassell, Lower Tribune Cases 15 000072\n25 which shows that that matter is still pending. There is",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003830",
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  "entities": {
    "people": [
      "MR. EDWARDS",
      "THE COURT",
      "MR. CASSELL",
      "MR. PAGLIUCA",
      "Brad Edwards",
      "Paul G. Cassell",
      "Epstein"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "Florida"
    ],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "212-2",
      "15 000072",
      "DOJ-OGR-00003830"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}