{
  "document_metadata": {
    "page_number": "17",
    "document_number": "212-2",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 17 of 30 App.-0820 G4LMGIUC 16 1 case. 2 Your Honor, we have complied with our production. We 3 have produced the materials that she is saying we have not 4 produced. It's incorrect. We have produced her school records 5 that we have. We have produced her tax records that we have. 6 We have produced all of those items that we have. 7 With respect to her medical records I am going to 8 direct you to the case that is cited in our brief as the Evanko 9 case and it was a similar circumstance to here. It was a Title 10 VII case where there were emotional distress damages being 11 alleged and the Court found that the other side could not have 12 carte blanche ruling over all of her medical records from the 13 time she was born to the present. We met and conferred on two 14 hours on their discovery requests, your Honor. We agreed to 15 produce all of her medical records that we had from 1999 to 16 2002 and anything else we had that was related to the sexual 17 abuse she endured at the hands of the defendant and 18 Mr. Epstein. We have agreed to produce those. 19 We have already started producing those records from 20 the various doctors, from the treating physicians. Those are 21 in their production. Should they be entitled to the things that 22 happened prior to that? Absolutely not, your Honor. They are 23 not entitled to a full-scale production of everything that's 24 happened in this young lady's life. She was abused by these 25 individuals. She shouldn't be reabused by having to disclose SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00003819",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 17 of 30 App.-0820",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "G4LMGIUC 16 1 case. 2 Your Honor, we have complied with our production. We 3 have produced the materials that she is saying we have not 4 produced. It's incorrect. We have produced her school records 5 that we have. We have produced her tax records that we have. 6 We have produced all of those items that we have. 7 With respect to her medical records I am going to 8 direct you to the case that is cited in our brief as the Evanko 9 case and it was a similar circumstance to here. It was a Title 10 VII case where there were emotional distress damages being 11 alleged and the Court found that the other side could not have 12 carte blanche ruling over all of her medical records from the 13 time she was born to the present. We met and conferred on two 14 hours on their discovery requests, your Honor. We agreed to 15 produce all of her medical records that we had from 1999 to 16 2002 and anything else we had that was related to the sexual 17 abuse she endured at the hands of the defendant and 18 Mr. Epstein. We have agreed to produce those. 19 We have already started producing those records from 20 the various doctors, from the treating physicians. Those are 21 in their production. Should they be entitled to the things that 22 happened prior to that? Absolutely not, your Honor. They are 23 not entitled to a full-scale production of everything that's 24 happened in this young lady's life. She was abused by these 25 individuals. She shouldn't be reabused by having to disclose",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003819",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mr. Epstein"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "04/16/21",
      "1999",
      "2002"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "212-2",
      "DOJ-OGR-00003819"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document related to a case involving sexual abuse. The text is typed and there are no visible handwritten notes or stamps. The document is from the Southern District Reporters, P.C. and includes a case number and document number."
}