{ "document_metadata": { "page_number": "54", "document_number": "745", "date": "08/10/22", "document_type": "court transcript", "has_handwriting": false, "has_stamps": false }, "full_text": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 54 of 264 460 LC1Qmax2 Jane - Cross 1 (At the sidebar) 2 MS. MODE: Thank you, your Honor. And I apologize for 3 asking for a sidebar, but I'm hoping this will streamline 4 things. The issue is at a number of times the witness has 5 testified that she doesn't recall, and instead of showing the 6 witness the document and asking if that refreshes her 7 recollection, which is the only thing that would be proper at 8 that juncture, I believe counsel is now just reading reports 9 into the record, which is not proper. 10 THE COURT: Well, the question was yesterday you 11 testified -- 12 (Pause) 13 THE COURT: So, yes, she said she didn't remember if 14 Epstein directed where they sat. 15 MS. MENNINGER: Your Honor, under 613, I'm not 16 obligated to show the witness a prior statement before I ask 17 her about it. I have to give her an opportunity -- 18 THE COURT: She said she didn't remember. What's the 19 inconsistency? 20 MS. MENNINGER: Well, your Honor, her not remembering 21 I don't have to refresh her recollection. Her memory is at 22 issue in this case. If she can't remember what she said a 23 month ago or two months ago or a year ago, that's relevant to 24 the jury's determination. Then we can put on evidence through 25 other witnesses that that is in fact what she said to the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00017663", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 54 of 264 460 LC1Qmax2 Jane - Cross", "position": "header" }, { "type": "printed", "content": "(At the sidebar) MS. MODE: Thank you, your Honor. And I apologize for asking for a sidebar, but I'm hoping this will streamline things. The issue is at a number of times the witness has testified that she doesn't recall, and instead of showing the witness the document and asking if that refreshes her recollection, which is the only thing that would be proper at that juncture, I believe counsel is now just reading reports into the record, which is not proper. THE COURT: Well, the question was yesterday you testified -- (Pause) THE COURT: So, yes, she said she didn't remember if Epstein directed where they sat. MS. MENNINGER: Your Honor, under 613, I'm not obligated to show the witness a prior statement before I ask her about it. I have to give her an opportunity -- THE COURT: She said she didn't remember. What's the inconsistency? MS. MENNINGER: Well, your Honor, her not remembering I don't have to refresh her recollection. Her memory is at issue in this case. If she can't remember what she said a month ago or two months ago or a year ago, that's relevant to the jury's determination. Then we can put on evidence through other witnesses that that is in fact what she said to the", "position": "main content" }, { "type": "printed", "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300", "position": "footer" }, { "type": "printed", "content": "DOJ-OGR-00017663", "position": "footer" } ], "entities": { "people": [ "MS. MODE", "THE COURT", "MS. MENNINGER", "Epstein" ], "organizations": [ "SOUTHERN DISTRICT REPORTERS, P.C." ], "locations": [], "dates": [ "08/10/22" ], "reference_numbers": [ "1:20-cr-00330-PAE", "745", "613", "DOJ-OGR-00017663" ] }, "additional_notes": "The document appears to be a court transcript with a discussion between the court and lawyers regarding a witness's testimony. The text is mostly clear, but there may be some minor formatting issues due to the original document's layout." }