{
  "document_metadata": {
    "page_number": "24",
    "document_number": "212-2",
    "date": "04/16/21",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 24 of 30\nApp.-0827\n23\n1 years and years ago. The recent doctors we have disclosed they\n2 have noticed for deposition.\n3 THE COURT: What else?\n4 MS. MENNINGER: Your Honor, with respect to the\n5 employment and education records, as you heard plaintiff say,\n6 she has disclosed, quote/unquote, what she has. Under local\n7 rule 33.3, we are allowed to ask for the names of witnesses\n8 with knowledge at the outset of the case, and they might be\n9 custodians of records. We asked her who have been your\n10 employers. She won't tell us who her employers have been. She\n11 has just gone through her computer and say if I have an\n12 employment record I'll give it to you, but I am not going to\n13 tell you who her employers were.\n14 THE COURT: She will.\n15 MS. MENNINGER: Same thing with the education records.\n16 We asked her to list where she had gone to school and tell us\n17 where it is. She won't do it. Those are the things where my\n18 skepticism arises from.\n19 Largely, to the extent your Honor has ordered the\n20 production of whatever materials, criminal investigation\n21 materials that were not to be submitted in camera, those were\n22 the ones that involved plaintiff's statements, we would like\n23 the other materials that they have brought with them today to\n24 give to your Honor that do not encompass their client's\n25 statements to law enforcement.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00003826",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 24 of 30",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "App.-0827",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "23\n1 years and years ago. The recent doctors we have disclosed they\n2 have noticed for deposition.\n3 THE COURT: What else?\n4 MS. MENNINGER: Your Honor, with respect to the\n5 employment and education records, as you heard plaintiff say,\n6 she has disclosed, quote/unquote, what she has. Under local\n7 rule 33.3, we are allowed to ask for the names of witnesses\n8 with knowledge at the outset of the case, and they might be\n9 custodians of records. We asked her who have been your\n10 employers. She won't tell us who her employers have been. She\n11 has just gone through her computer and say if I have an\n12 employment record I'll give it to you, but I am not going to\n13 tell you who her employers were.\n14 THE COURT: She will.\n15 MS. MENNINGER: Same thing with the education records.\n16 We asked her to list where she had gone to school and tell us\n17 where it is. She won't do it. Those are the things where my\n18 skepticism arises from.\n19 Largely, to the extent your Honor has ordered the\n20 production of whatever materials, criminal investigation\n21 materials that were not to be submitted in camera, those were\n22 the ones that involved plaintiff's statements, we would like\n23 the other materials that they have brought with them today to\n24 give to your Honor that do not encompass their client's\n25 statements to law enforcement.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003826",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "MS. MENNINGER"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "212-2",
      "App.-0827",
      "DOJ-OGR-00003826"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}