{ "document_metadata": { "page_number": "16", "document_number": "136", "date": "02/04/21", "document_type": "court document", "has_handwriting": false, "has_stamps": false }, "full_text": "Case 1:20-cr-00330-AJN Document 136 Filed 02/04/21 Page 16 of 27\n\n2. The Second Question: \"List all of the people under the age of 18 that you interacted with at any of Jeffrey's properties?\"\n\nThe second \"question\" was equally improper. First, this is not a question. Rather, it is a demand to do something, make a list. Fed. R. Civ. P. 30(a)(1) limits a deposition to \"oral questions.\" The question was grossly ambiguous: who was \"Jeffrey\"; what were \"Jeffrey's properties;\" to what time frame did the question apply; what was the basis for Ms. Maxwell to determine who may or may not have been \"under the age of 18\"; and what did \"interact with\" mean?\n\nAgain, the Government selectively omits objections, context, and relevant colloquy. This series of questions begins at page 382 of the April 2016 deposition:\n\n[REDACTED TEXT BLOCK]\n\n11\nDOJ-OGR-00002425", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cr-00330-AJN Document 136 Filed 02/04/21 Page 16 of 27", "position": "header" }, { "type": "printed", "content": "2. The Second Question: \"List all of the people under the age of 18 that you interacted with at any of Jeffrey's properties?\"", "position": "top" }, { "type": "printed", "content": "The second \"question\" was equally improper. First, this is not a question. Rather, it is a demand to do something, make a list. Fed. R. Civ. P. 30(a)(1) limits a deposition to \"oral questions.\" The question was grossly ambiguous: who was \"Jeffrey\"; what were \"Jeffrey's properties;\" to what time frame did the question apply; what was the basis for Ms. Maxwell to determine who may or may not have been \"under the age of 18\"; and what did \"interact with\" mean?", "position": "middle" }, { "type": "printed", "content": "Again, the Government selectively omits objections, context, and relevant colloquy. This series of questions begins at page 382 of the April 2016 deposition:", "position": "middle" }, { "type": "other", "content": "[REDACTED TEXT BLOCK]", "position": "middle" }, { "type": "printed", "content": "11", "position": "footer" }, { "type": "printed", "content": "DOJ-OGR-00002425", "position": "footer" } ], "entities": { "people": [ "Jeffrey", "Ms. Maxwell" ], "organizations": [ "Government" ], "locations": [], "dates": [ "02/04/21", "April 2016" ], "reference_numbers": [ "1:20-cr-00330-AJN", "Document 136", "Page 16 of 27", "DOJ-OGR-00002425", "382" ] }, "additional_notes": "The document contains redactions in the form of blacked-out text blocks. The quality of the document is otherwise clear and legible." }