{
  "document_metadata": {
    "page_number": "3",
    "document_number": "545",
    "date": "12/15/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 545 Filed 12/15/21 Page 3 of 9\n(AKT), 2017 WL 3037408, at *9 (E.D.N.Y. July 17, 2017) (\"[T]here is a presumption disfavoring attorney depositions which is based on the recognition that even a deposition of counsel limited to relevant and non-privileged information risks disrupting the attorney-client relationship and impeding the litigation.\") (alterations and internal quotation marks omitted)); ABA Model Rule 3.7 cmt. (noting potential conflict of interest issues that arise if, for instance, \"there is likely to be substantial conflict between the testimony of the client and that of the lawyer\").\n\nII. Discussion\nThe defendant seeks to call three attorneys for victims: Jack Scarola, Brad Edwards, and Robert Glassman. For each, the proposed testimony is either duplicative of facts already in evidence, is irrelevant or is improper impeachment. And in any event, whatever marginal probative value that testimony might offer is outweighed by the prejudice and jury confusion associated with calling an attorney to testify against his client.\n\nA. Jack Scarola\nThe defendant proposes to call Jack Scarola, counsel for Carolyn, to testify about the course of his communications with the Government. While that testimony would not be privileged, it is irrelevant and improper impeachment.\nMuch of the testimony the defendant seeks from Scarola is evidence confirmed by Carolyn on cross-examination. Specifically, Carolyn agreed to the following facts:\n- Jack Scarola represented Carolyn in her 2008 lawsuit and before the Epstein Victims Compensation Program. (Tr. 1617-18).\n- Carolyn did not contact the Government between 2007 and March 2019, and then again was out of touch until her representative, Mr. Danchuck, responded in July 2020. (Tr.\n3\nDOJ-OGR-00008376",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 545 Filed 12/15/21 Page 3 of 9",
      "position": "header"
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    {
      "type": "printed",
      "content": "(AKT), 2017 WL 3037408, at *9 (E.D.N.Y. July 17, 2017) (\"[T]here is a presumption disfavoring attorney depositions which is based on the recognition that even a deposition of counsel limited to relevant and non-privileged information risks disrupting the attorney-client relationship and impeding the litigation.\") (alterations and internal quotation marks omitted)); ABA Model Rule 3.7 cmt. (noting potential conflict of interest issues that arise if, for instance, \"there is likely to be substantial conflict between the testimony of the client and that of the lawyer\").",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "II. Discussion",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The defendant seeks to call three attorneys for victims: Jack Scarola, Brad Edwards, and Robert Glassman. For each, the proposed testimony is either duplicative of facts already in evidence, is irrelevant or is improper impeachment. And in any event, whatever marginal probative value that testimony might offer is outweighed by the prejudice and jury confusion associated with calling an attorney to testify against his client.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A. Jack Scarola",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant proposes to call Jack Scarola, counsel for Carolyn, to testify about the course of his communications with the Government. While that testimony would not be privileged, it is irrelevant and improper impeachment.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Much of the testimony the defendant seeks from Scarola is evidence confirmed by Carolyn on cross-examination. Specifically, Carolyn agreed to the following facts:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- Jack Scarola represented Carolyn in her 2008 lawsuit and before the Epstein Victims Compensation Program. (Tr. 1617-18).\n- Carolyn did not contact the Government between 2007 and March 2019, and then again was out of touch until her representative, Mr. Danchuck, responded in July 2020. (Tr.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "3",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008376",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jack Scarola",
      "Brad Edwards",
      "Robert Glassman",
      "Carolyn",
      "Mr. Danchuck"
    ],
    "organizations": [
      "Government",
      "Epstein Victims Compensation Program"
    ],
    "locations": [
      "E.D.N.Y."
    ],
    "dates": [
      "July 17, 2017",
      "2007",
      "March 2019",
      "July 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "545",
      "2017 WL 3037408",
      "DOJ-OGR-00008376"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 3 of 9."
}