mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00007168.json

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    "page_number": "117",
    "document_number": "465",
    "date": "11/15/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 117 of 127 117 LB15max4 have all our facts straight about the exact timeline. So I am happy to address that in the letter. THE COURT: Yes, do address that in the letter. Is there anything the government can do -- you know, there is going to be some time built in for the facilities screening process and it getting to the defendant. Obviously there are other individuals in the same situation pretrial, heading into trial, and there are a lot of inmates, but -- so you will address what's happening on the institution side in the letter. What can the government do to facilitate the process going forward? MS. MODE: Your Honor, we have been trying to produce materials as quickly as possible. We have been FedExing those materials promptly to the facility. When we do so, we notify the facility that, in particular, a disclosure for this defendant is in-bound to the facility so that legal counsel knows about it and can keep an eye out for it which I think is unusual but we are happy to continue to take that step in this case. My understanding is that materials have been received by the defendant at the facility. We will continue to check on that issue. I would note that our rolling productions are going to be frequent but also small as we continue to meet with witnesses and produce small amounts of rolling materials. I SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007168",
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      "content": "have all our facts straight about the exact timeline. So I am happy to address that in the letter. THE COURT: Yes, do address that in the letter. Is there anything the government can do -- you know, there is going to be some time built in for the facilities screening process and it getting to the defendant. Obviously there are other individuals in the same situation pretrial, heading into trial, and there are a lot of inmates, but -- so you will address what's happening on the institution side in the letter. What can the government do to facilitate the process going forward? MS. MODE: Your Honor, we have been trying to produce materials as quickly as possible. We have been FedExing those materials promptly to the facility. When we do so, we notify the facility that, in particular, a disclosure for this defendant is in-bound to the facility so that legal counsel knows about it and can keep an eye out for it which I think is unusual but we are happy to continue to take that step in this case. My understanding is that materials have been received by the defendant at the facility. We will continue to check on that issue. I would note that our rolling productions are going to be frequent but also small as we continue to meet with witnesses and produce small amounts of rolling materials. I",
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    "dates": [
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