mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00016167.json

{
  "document_metadata": {
    "page_number": "57",
    "document_number": "741",
    "date": "08/10/22",
    "document_type": "court transcript",
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  "full_text": "Case 1:20-cr-00330-AJN Document 741 Filed 08/10/22 Page 57 of 106\nLBTVMAX3\n61\nOpening - Ms. Sternheim\ntopics to ask the client about. That certainly couldn't be a\ngood-faith basis to suggest to this jury that there will be\nevidence before them at this trial; that these were more\nmanipulated by their attorneys who cultivated their specific\nstories told to the government. We think that's inappropriate,\nyour Honor.\nTHE COURT: I'm going to overrule it at the opening\nstage. I did not preclude the line of argumentation; I wasn't\nasked to preclude the line of argumentation. You raised the\nprospect -- you did certainly and I appreciate it, raise the\nprospect related to a subpoena of a witness's attorney, which I\nagree with the government is entirely unclear to me how that\nwould be able -- but if the proffers that it's based on\nexisting nonprivileged information from which the jury could\ninfer that these attorneys structured in some way the questions\nthat were asked, I think the line is I don't think you have any\nbasis to say that the attorneys told the witnesses what to say.\nWhat evidence are you going to put in that shows the\nattorneys told the witnesses what to say?\nMR. PAGLIUCA: Well, so we back up a little bit, your\nHonor. We have in 2008 -- I'll use Carolyn as the example --\nanswers to interrogatories that are detailed that do not\ninclude Ms. Maxwell; deposition testimony that is detailed but\ndoes not include Ms. Maxwell; a 91-page complaint detailed, but\ndoes not include Ms. Maxwell.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00016167",
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      "content": "Case 1:20-cr-00330-AJN Document 741 Filed 08/10/22 Page 57 of 106",
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    {
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      "content": "LBTVMAX3\n61\nOpening - Ms. Sternheim",
      "position": "header"
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    {
      "type": "printed",
      "content": "topics to ask the client about. That certainly couldn't be a\ngood-faith basis to suggest to this jury that there will be\nevidence before them at this trial; that these were more\nmanipulated by their attorneys who cultivated their specific\nstories told to the government. We think that's inappropriate,\nyour Honor.",
      "position": "main content"
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    {
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      "content": "THE COURT: I'm going to overrule it at the opening\nstage. I did not preclude the line of argumentation; I wasn't\nasked to preclude the line of argumentation. You raised the\nprospect -- you did certainly and I appreciate it, raise the\nprospect related to a subpoena of a witness's attorney, which I\nagree with the government is entirely unclear to me how that\nwould be able -- but if the proffers that it's based on\nexisting nonprivileged information from which the jury could\ninfer that these attorneys structured in some way the questions\nthat were asked, I think the line is I don't think you have any\nbasis to say that the attorneys told the witnesses what to say.\nWhat evidence are you going to put in that shows the\nattorneys told the witnesses what to say?",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "MR. PAGLIUCA: Well, so we back up a little bit, your\nHonor. We have in 2008 -- I'll use Carolyn as the example --\nanswers to interrogatories that are detailed that do not\ninclude Ms. Maxwell; deposition testimony that is detailed but\ndoes not include Ms. Maxwell; a 91-page complaint detailed, but\ndoes not include Ms. Maxwell.",
      "position": "main content"
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00016167",
      "position": "footer"
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  "entities": {
    "people": [
      "Ms. Sternheim",
      "Carolyn",
      "Ms. Maxwell",
      "MR. PAGLIUCA"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22",
      "2008"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "741",
      "DOJ-OGR-00016167"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}