{ "document_metadata": { "page_number": "67", "document_number": "765", "date": "08/10/22", "document_type": "court transcript", "has_handwriting": false, "has_stamps": false }, "full_text": "Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 67 of 95 2805 LCIAMAX2ps\n1 MR. PAGLIUCA: I think I disagree with that, your Honor. And let's take Carolyn as the example. Carolyn, the government affirmatively elicited that she was told by Virginia to say that she was, you know, whatever age she was told to say. That's, I think, the government's testimony.\n2 MR. ROHRBACH: I believe that came out on cross, your Honor. It's on page 1569.\n3 MR. PAGLIUCA: If it came out on cross, it was her volunteering that information, I think.\n4 But anyway, that doesn't have anything to do with Ms. Maxwell. I mean, that's simply \"Virginia told me whatever my name -- whatever the age I'm supposed to say.\" It's not Ms. Maxwell saying to Virginia, \"Say this age.\"\n5 So I just disagree as a factual matter that this has anything to do with conscious avoidance.\n6 MR. ROHRBACH: The defense also elicited testimony that the defendant was from -- through Mr. Alessi -- that the defendant was going to legitimate hotels to identify massage therapists. I assume that that's in service of an argument that she didn't know the ages of people coming to the house as massage therapists, and so she could have confused some of them who were under the age of consent with ones who were older than the age of consent. I'm not sure what other evidence that would be in service of.\n7 MR. PAGLIUCA: Well, that's in service of Ms. Roberts\n8 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n9 DOJ-OGR-00014371", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 67 of 95 2805 LCIAMAX2ps", "position": "header" }, { "type": "printed", "content": "1 MR. PAGLIUCA: I think I disagree with that, your Honor. And let's take Carolyn as the example. Carolyn, the government affirmatively elicited that she was told by Virginia to say that she was, you know, whatever age she was told to say. That's, I think, the government's testimony.\n2 MR. ROHRBACH: I believe that came out on cross, your Honor. It's on page 1569.\n3 MR. PAGLIUCA: If it came out on cross, it was her volunteering that information, I think.\n4 But anyway, that doesn't have anything to do with Ms. Maxwell. I mean, that's simply \"Virginia told me whatever my name -- whatever the age I'm supposed to say.\" It's not Ms. Maxwell saying to Virginia, \"Say this age.\"\n5 So I just disagree as a factual matter that this has anything to do with conscious avoidance.\n6 MR. ROHRBACH: The defense also elicited testimony that the defendant was from -- through Mr. Alessi -- that the defendant was going to legitimate hotels to identify massage therapists. I assume that that's in service of an argument that she didn't know the ages of people coming to the house as massage therapists, and so she could have confused some of them who were under the age of consent with ones who were older than the age of consent. I'm not sure what other evidence that would be in service of.\n7 MR. PAGLIUCA: Well, that's in service of Ms. Roberts", "position": "main" }, { "type": "printed", "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300", "position": "footer" }, { "type": "printed", "content": "DOJ-OGR-00014371", "position": "footer" } ], "entities": { "people": [ "MR. PAGLIUCA", "MR. ROHRBACH", "Carolyn", "Virginia", "Ms. Maxwell", "Mr. Alessi", "Ms. Roberts" ], "organizations": [ "SOUTHERN DISTRICT REPORTERS, P.C." ], "locations": [], "dates": [ "08/10/22" ], "reference_numbers": [ "1:20-cr-00330-PAE", "765", "1569", "DOJ-OGR-00014371" ] }, "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage." }