{
  "document_metadata": {
    "page_number": "78",
    "document_number": "20-2",
    "date": "04/01/2021",
    "document_type": "court transcript",
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    "has_stamps": false
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  "full_text": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page78 of 200\n\n1 THE COURT: Among other things, but, yes, I'm drilling\n2 down specifically on that since that has been, in somewhat\n3 comparable circumstances in other matters, the source of issues\n4 related to timely disclosures.\n5 MS. MOE: Yes, your Honor. Our team met personally\n6 with the F.B.I. in Florida to make sure that we had the\n7 materials, and it was represented to us that the materials that\n8 the F.B.I. provided in Florida were the comprehensive set of\n9 materials. We will certainly have ongoing conversations to\n10 make sure that that is the case and if, in our review of files,\n11 we discover other materials, we will handle that with great\n12 care, and we are particularly sensitive to that concern.\n13 THE COURT: And I expect here, and in all matters, not\n14 just accepting of initial representations made regarding full\n15 disclosure, but thoughtful and critical pushing and pressing of\n16 questions and issues with respect to actively retrieving any\n17 appropriate files. Are we on the same page, Ms. Moe?\n18 MS. MOE: Yes, your Honor. Very much so.\n19 THE COURT: All right. Thank you.\n20 With that, why don't you go ahead and lay out the\n21 proposed schedule that you have discussed with Mr. Cohen, and\n22 then I will hear from Mr. Cohen if he has any concerns with\n23 that proposal.\n24 MS. MOE: Yes, your Honor.\n25 We would propose the completion of discovery, to\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00001019",
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      "content": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page78 of 200",
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    {
      "type": "printed",
      "content": "1 THE COURT: Among other things, but, yes, I'm drilling down specifically on that since that has been, in somewhat comparable circumstances in other matters, the source of issues related to timely disclosures.",
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      "content": "5 MS. MOE: Yes, your Honor. Our team met personally with the F.B.I. in Florida to make sure that we had the materials, and it was represented to us that the materials that the F.B.I. provided in Florida were the comprehensive set of materials. We will certainly have ongoing conversations to make sure that that is the case and if, in our review of files, we discover other materials, we will handle that with great care, and we are particularly sensitive to that concern.",
      "position": "main"
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    {
      "type": "printed",
      "content": "13 THE COURT: And I expect here, and in all matters, not just accepting of initial representations made regarding full disclosure, but thoughtful and critical pushing and pressing of questions and issues with respect to actively retrieving any appropriate files. Are we on the same page, Ms. Moe?",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "18 MS. MOE: Yes, your Honor. Very much so.",
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    {
      "type": "printed",
      "content": "19 THE COURT: All right. Thank you. With that, why don't you go ahead and lay out the proposed schedule that you have discussed with Mr. Cohen, and then I will hear from Mr. Cohen if he has any concerns with that proposal.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "24 MS. MOE: Yes, your Honor. We would propose the completion of discovery, to",
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001019",
      "position": "footer"
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  "entities": {
    "people": [
      "Ms. Moe",
      "Mr. Cohen"
    ],
    "organizations": [
      "F.B.I.",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "Florida"
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    "dates": [
      "04/01/2021"
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    "reference_numbers": [
      "Case 21-770",
      "Document 20-2",
      "3068530",
      "DOJ-OGR-00001019"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}