mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00022010.json

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    "page_number": "7",
    "document_number": "26",
    "date": "02/10/20",
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  "full_text": "Case 1:19-cr-00830-AT Document 26 Filed 02/10/20 Page 7 of 15 7 k1u2NoeC kjc 1 THE COURT: I will hear from the government. 2 MS. LONERGAN: Yes, your Honor. As we put in our 3 written submission to the court, we agree that a brief 4 adjournment is appropriate, but we do not think that a 5 six-month adjournment is necessary or warranted. 6 First, the amount of discovery in this case is not 7 particularly voluminous nor complex in light of the cases tried 8 in this district; and, in addition, the further investigation, 9 I want to focus the court on the facts that are going to be at 10 issue in this trial occurred over a 14-hour period. It is true 11 that, as part of our discovery, we provided information outside 12 of that 14-hour period, anticipating many of the types of 13 requests that the defense counsel has already begun to make. 14 But again, your Honor, this is a very focused, single-incident 15 indictment that is about what happened over the period of 14 16 hours. A much larger investigation about, for example, the 17 working conditions at the MCC, it is just not relevant to what 18 is going to be the issues on trial here. 19 I want to also touch on something that plaintiff said 20 about the need to interview witnesses. As we explained to the 21 court, we have done something that's unusual here, which is 22 that we have provided witness statements with our initial 23 discovery almost four months in advance of trial. As the court 24 is aware, we typically provide what we call 3500 material much 25 closer to trial. So the need to review those witness SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00022010",
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      "content": "1 THE COURT: I will hear from the government. 2 MS. LONERGAN: Yes, your Honor. As we put in our 3 written submission to the court, we agree that a brief 4 adjournment is appropriate, but we do not think that a 5 six-month adjournment is necessary or warranted. 6 First, the amount of discovery in this case is not 7 particularly voluminous nor complex in light of the cases tried 8 in this district; and, in addition, the further investigation, 9 I want to focus the court on the facts that are going to be at 10 issue in this trial occurred over a 14-hour period. It is true 11 that, as part of our discovery, we provided information outside 12 of that 14-hour period, anticipating many of the types of 13 requests that the defense counsel has already begun to make. 14 But again, your Honor, this is a very focused, single-incident 15 indictment that is about what happened over the period of 14 16 hours. A much larger investigation about, for example, the 17 working conditions at the MCC, it is just not relevant to what 18 is going to be the issues on trial here. 19 I want to also touch on something that plaintiff said 20 about the need to interview witnesses. As we explained to the 21 court, we have done something that's unusual here, which is 22 that we have provided witness statements with our initial 23 discovery almost four months in advance of trial. As the court 24 is aware, we typically provide what we call 3500 material much 25 closer to trial. So the need to review those witness",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00022010",
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  "entities": {
    "people": [
      "MS. LONERGAN"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
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    "dates": [
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      "26",
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