{
  "document_metadata": {
    "page_number": "91",
    "document_number": "751",
    "date": "08/10/22",
    "document_type": "court transcript",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 751 Filed 08/10/22 Page 91 of 261 1252\nLC6Cmax3 Kate - cross\n1 Q. I apologize. I don't mean promoting. I mean promoting sobriety and support for women who had also had addictions?\n2 A. I think it's what we offer or what we offered when the foundation was still going.\n3 Q. Understood.\n4 A. Yes.\n5 Q. Fair to say that using and abusing those substances over a ten-year period has had an impact on memory; correct?\n6 A. It has not had an impact on the memories that I have always had.\n7 Q. The memories that you have always had are your personal memories; correct?\n8 A. Yes.\n9 Q. And memories based upon your perception of experiences; correct?\n10 A. Well, they're just based on my experience.\n11 Q. But you have testified today about experiences during a period of time where you were abusing drugs; correct?\n12 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.\n13 Q. Because you knew that they did not tolerate drug use; correct?\n14 A. That was what was required.\n15 Q. You knew that they did not tolerate drug use; correct?\n16 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00012842",
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      "content": "Case 1:20-cr-00330-PAE Document 751 Filed 08/10/22 Page 91 of 261 1252",
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    {
      "type": "printed",
      "content": "LC6Cmax3 Kate - cross",
      "position": "header"
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    {
      "type": "printed",
      "content": "1 Q. I apologize. I don't mean promoting. I mean promoting sobriety and support for women who had also had addictions?\n2 A. I think it's what we offer or what we offered when the foundation was still going.\n3 Q. Understood.\n4 A. Yes.\n5 Q. Fair to say that using and abusing those substances over a ten-year period has had an impact on memory; correct?\n6 A. It has not had an impact on the memories that I have always had.\n7 Q. The memories that you have always had are your personal memories; correct?\n8 A. Yes.\n9 Q. And memories based upon your perception of experiences; correct?\n10 A. Well, they're just based on my experience.\n11 Q. But you have testified today about experiences during a period of time where you were abusing drugs; correct?\n12 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.\n13 Q. Because you knew that they did not tolerate drug use; correct?\n14 A. That was what was required.\n15 Q. You knew that they did not tolerate drug use; correct?",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00012842",
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  ],
  "entities": {
    "people": [
      "Ghislaine",
      "Jeffrey"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "751",
      "DOJ-OGR-00012842"
    ]
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}