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    "page_number": "91",
    "document_number": "751",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 751 Filed 08/10/22 Page 91 of 261 1252 LC6Cmax3 Kate - cross Q. I apologize. I don't mean promoting. I mean promoting sobriety and support for women who had also had addictions? A. I think it's what we offer or what we offered when the foundation was still going. Q. Understood. A. Yes. Q. Fair to say that using and abusing those substances over a ten-year period has had an impact on memory; correct? A. It has not had an impact on the memories that I have always had. Q. The memories that you have always had are your personal memories; correct? A. Yes. Q. And memories based upon your perception of experiences; correct? A. Well, they're just based on my experience. Q. But you have testified today about experiences during a period of time where you were abusing drugs; correct? A. The memories that I testified to were at periods when I was always sober because I was always required to not take drugs and not be drunk around Ghislaine and Jeffrey. Q. Because you knew that they did not tolerate drug use; correct? A. That was what was required. Q. You knew that they did not tolerate drug use; correct? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00018428",
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      "type": "printed",
      "content": "LC6Cmax3 Kate - cross",
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    {
      "type": "printed",
      "content": "Q. I apologize. I don't mean promoting. I mean promoting sobriety and support for women who had also had addictions? A. I think it's what we offer or what we offered when the foundation was still going. Q. Understood. A. Yes. Q. Fair to say that using and abusing those substances over a ten-year period has had an impact on memory; correct? A. It has not had an impact on the memories that I have always had. Q. The memories that you have always had are your personal memories; correct? A. Yes. Q. And memories based upon your perception of experiences; correct? A. Well, they're just based on my experience. Q. But you have testified today about experiences during a period of time where you were abusing drugs; correct? A. The memories that I testified to were at periods when I was always sober because I was always required to not take drugs and not be drunk around Ghislaine and Jeffrey. Q. Because you knew that they did not tolerate drug use; correct? A. That was what was required. Q. You knew that they did not tolerate drug use; correct?",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00018428",
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  "entities": {
    "people": [
      "Ghislaine",
      "Jeffrey"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
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      "1:20-cr-00330-PAE",
      "751",
      "DOJ-OGR-00018428"
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}