mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008413.json

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    "page_number": "19",
    "document_number": "549-1",
    "date": "12/17/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 549-1 Filed 12/17/21 Page 19 of 24 31 LB15MAX2\n1 sense to address this issue at the same time.\n2 MS. STERNHEIM: We agree.\n3 THE COURT: So we will defer on that. In light of the\n4 overlap on the 412 issues we will take that up at the 412\n5 hearing.\n6 Government's 7. The government argues that before\n7 offering evidence or argument of Ms. Maxwell's failure to\n8 commit other bad acts it should require the defense to proffer\n9 the basis and the relevance of such evidence. Let me hear from\n10 the government what the specific concern is here and then I\n11 will speak to the defense.\n12 MS. MOE: Yes, your Honor. Thank you.\n13 The concern here is what the defense has flagged in\n14 its opening papers relating to statements by other victims who\n15 were interviewed during the course of the government's\n16 investigation. Evidence along those lines, if proffered in an\n17 opening statement, or if asked about in cross-examination of a\n18 law enforcement officer, would be inappropriate and hearsay.\n19 Such evidence could only come in at trial, if at all, if the\n20 defense called, as defense witnesses, victims who were not at\n21 issue in this case. And so, for that reason, your Honor, the\n22 defense should be precluded from opening on this issue unless\n23 and until they proffer which victims these statements would\n24 come through, who they would anticipate calling as defense\n25 witnesses at trial so the Court can assess whether that is\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00008413",
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      "content": "1 sense to address this issue at the same time.\n2 MS. STERNHEIM: We agree.\n3 THE COURT: So we will defer on that. In light of the\n4 overlap on the 412 issues we will take that up at the 412\n5 hearing.\n6 Government's 7. The government argues that before\n7 offering evidence or argument of Ms. Maxwell's failure to\n8 commit other bad acts it should require the defense to proffer\n9 the basis and the relevance of such evidence. Let me hear from\n10 the government what the specific concern is here and then I\n11 will speak to the defense.\n12 MS. MOE: Yes, your Honor. Thank you.\n13 The concern here is what the defense has flagged in\n14 its opening papers relating to statements by other victims who\n15 were interviewed during the course of the government's\n16 investigation. Evidence along those lines, if proffered in an\n17 opening statement, or if asked about in cross-examination of a\n18 law enforcement officer, would be inappropriate and hearsay.\n19 Such evidence could only come in at trial, if at all, if the\n20 defense called, as defense witnesses, victims who were not at\n21 issue in this case. And so, for that reason, your Honor, the\n22 defense should be precluded from opening on this issue unless\n23 and until they proffer which victims these statements would\n24 come through, who they would anticipate calling as defense\n25 witnesses at trial so the Court can assess whether that is",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "DOJ-OGR-00008413",
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  "entities": {
    "people": [
      "MS. STERNHEIM",
      "THE COURT",
      "MS. MOE",
      "Ms. Maxwell"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/17/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "549-1",
      "412",
      "7",
      "DOJ-OGR-00008413"
    ]
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}