{
  "document_metadata": {
    "page_number": "4",
    "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 4 of 30\nApp.-0807\n\nG4LMGIUC\n3\n1 in Utah. He will be able to handle the Colorado depositions\n2 and things of that nature. We are here because those pro hac\n3 vice motions are being contested. The core piece of that is\n4 the argument that they should not be allowed to seek\n5 confidential information in this case.\n6 Your Honor will remember that I was before you a\n7 couple of weeks ago again trying to get the deposition of the\n8 defendant, which is set for tomorrow, but still hasn't occurred\n9 yet. And in order to expedite that process I agreed to the\n10 protective order that was put in front of the Court and I\n11 waived all of my objections to that in order to be able to\n12 facilitate and move that deposition forward. That protective\n13 order provides that attorneys who are actively working on the\n14 case can receive confidential material.\n15 My opposing counsel has interpreted that to mean that\n16 that must be a counsel of record in the case. We disagree with\n17 that interpretation. I wouldn't have agreed to a protective\n18 order knowing that they were already working on the case. If\n19 that were the situation, as your Honor can understand in this\n20 case, the majority of the material has been marked\n21 confidential, so it would prohibit my cocounsel from working on\n22 behalf of their client.\n23 Your Honor, I'm here to request on behalf of my\n24 client, Virginia Giuffre, that she be entitled to have her\n25 counsel of record of choice in this matter. If your Honor will\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00003806",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 4 of 30",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "App.-0807",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "G4LMGIUC\n3\n1 in Utah. He will be able to handle the Colorado depositions\n2 and things of that nature. We are here because those pro hac\n3 vice motions are being contested. The core piece of that is\n4 the argument that they should not be allowed to seek\n5 confidential information in this case.\n6 Your Honor will remember that I was before you a\n7 couple of weeks ago again trying to get the deposition of the\n8 defendant, which is set for tomorrow, but still hasn't occurred\n9 yet. And in order to expedite that process I agreed to the\n10 protective order that was put in front of the Court and I\n11 waived all of my objections to that in order to be able to\n12 facilitate and move that deposition forward. That protective\n13 order provides that attorneys who are actively working on the\n14 case can receive confidential material.\n15 My opposing counsel has interpreted that to mean that\n16 that must be a counsel of record in the case. We disagree with\n17 that interpretation. I wouldn't have agreed to a protective\n18 order knowing that they were already working on the case. If\n19 that were the situation, as your Honor can understand in this\n20 case, the majority of the material has been marked\n21 confidential, so it would prohibit my cocounsel from working on\n22 behalf of their client.\n23 Your Honor, I'm here to request on behalf of my\n24 client, Virginia Giuffre, that she be entitled to have her\n25 counsel of record of choice in this matter. If your Honor will",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003806",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Virginia Giuffre"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "Utah",
      "Colorado"
    ],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "212-2",
      "DOJ-OGR-00003806"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document related to a case involving Virginia Giuffre. 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 phone number."
}