mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00016474.json

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    "page_number": "258",
    "document_number": "759",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 759 Filed 08/10/22 Page 258 of 267 2286 LCAVMAX8\n1    It would be something we speak with the government\n2    about and brief if we believe that the testimony elicited\n3    during the government's case would give rise to such testimony\n4    from any other attorney.\n5        MS. MOE: Yes, your Honor.\n6        We'd be happy to confer with the defense about any of\n7    these issues.\n8        Our view remains the same as it has been throughout\n9    this case, which is that there's no basis for calling\n10   plaintiffs' attorneys as defense witnesses. There's no basis\n11   for waiving attorney-client privilege. And the Court has been\n12   very clear that that issue should be briefed in full before any\n13   witnesses along those lines should be called. But, again,\n14   we're happy to confer with the defense about that.\n15       THE COURT: Okay. You'll confer.\n16       The one that's been teed up is where there's an\n17   email --\n18       MS. MOE: Yes, your Honor.\n19       THE COURT: -- between you all and which it appears,\n20   at least on the face of the email, that counsel made a\n21   disclosure.\n22       MS. MENNINGER: That's similar to other issues, your\n23   Honor.\n24       THE COURT: It's in that context that I've encouraged\n25   a stipulation as to what was relayed to the government.\n    SOUTHERN DISTRICT REPORTERS, P.C.\n    (212) 805-0300\n    DOJ-OGR-00016474",
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      "content": "1    It would be something we speak with the government\n2    about and brief if we believe that the testimony elicited\n3    during the government's case would give rise to such testimony\n4    from any other attorney.\n5        MS. MOE: Yes, your Honor.\n6        We'd be happy to confer with the defense about any of\n7    these issues.\n8        Our view remains the same as it has been throughout\n9    this case, which is that there's no basis for calling\n10   plaintiffs' attorneys as defense witnesses. There's no basis\n11   for waiving attorney-client privilege. And the Court has been\n12   very clear that that issue should be briefed in full before any\n13   witnesses along those lines should be called. But, again,\n14   we're happy to confer with the defense about that.\n15       THE COURT: Okay. You'll confer.\n16       The one that's been teed up is where there's an\n17   email --\n18       MS. MOE: Yes, your Honor.\n19       THE COURT: -- between you all and which it appears,\n20   at least on the face of the email, that counsel made a\n21   disclosure.\n22       MS. MENNINGER: That's similar to other issues, your\n23   Honor.\n24       THE COURT: It's in that context that I've encouraged\n25   a stipulation as to what was relayed to the government.",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "DOJ-OGR-00016474",
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  "entities": {
    "people": [
      "MS. MOE",
      "MS. MENNINGER",
      "THE COURT"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "08/10/22"
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      "1:20-cr-00330-PAE",
      "759",
      "DOJ-OGR-00016474"
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}