mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00016964.json

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    "page_number": "38",
    "document_number": "765",
    "date": "08/10/2022",
    "document_type": "court transcript",
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  "full_text": "Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 38 of 95 2776 LCI1MAX1 considered illegal sexual activity for the purposes of their deliberations. It's not as charged in the indictment. We're talking about New York law, so I don't know if that was made clear to the jury. MR. ROHRBACH: Your Honor, these instructions do not put before the jury any violation of any New Mexico offense whatsoever above or below the age of consent, so I think there's no risk that the jury is going to convict the defendant based on their concerns about a violation of a New York offense. MR. EVERDELL: That's not really the issue about what instructions to put before the jury. The testimony put before the jury, sexual contact between Jane and Epstein in New Mexico after what we believe is the age of consent in New Mexico, and so if -- THE COURT: That's why, I think, it's the same reason I gave limiting instructions as asked with respect to the testimony of Kate and Annie. I think what I'm hearing you say is, you meant to ask for a limiting instruction at that time? MR. EVERDELL: Well, your Honor, we knew from the proffered 3500s for the other witnesses what they were planning on testifying to, so we were able to request those at the time before the witnesses testified and brief those in limine. I didn't think we -- what we knew about Jane ahead of time was that she alleged that she traveled to New Mexico but that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00016964",
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      "content": "considered illegal sexual activity for the purposes of their deliberations. It's not as charged in the indictment. We're talking about New York law, so I don't know if that was made clear to the jury. MR. ROHRBACH: Your Honor, these instructions do not put before the jury any violation of any New Mexico offense whatsoever above or below the age of consent, so I think there's no risk that the jury is going to convict the defendant based on their concerns about a violation of a New York offense. MR. EVERDELL: That's not really the issue about what instructions to put before the jury. The testimony put before the jury, sexual contact between Jane and Epstein in New Mexico after what we believe is the age of consent in New Mexico, and so if -- THE COURT: That's why, I think, it's the same reason I gave limiting instructions as asked with respect to the testimony of Kate and Annie. I think what I'm hearing you say is, you meant to ask for a limiting instruction at that time? MR. EVERDELL: Well, your Honor, we knew from the proffered 3500s for the other witnesses what they were planning on testifying to, so we were able to request those at the time before the witnesses testified and brief those in limine. I didn't think we -- what we knew about Jane ahead of time was that she alleged that she traveled to New Mexico but that",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00016964",
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  "entities": {
    "people": [
      "Jane",
      "Epstein",
      "Kate",
      "Annie",
      "MR. ROHRBACH",
      "MR. EVERDELL"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "New York",
      "New Mexico"
    ],
    "dates": [
      "08/10/2022"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "765",
      "DOJ-OGR-00016964"
    ]
  },
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}