mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00016978.json

{
  "document_metadata": {
    "page_number": "52",
    "document_number": "765",
    "date": "08/10/22",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 52 of 95 2790 LCI1MAX1\n1 brackets or something.\n2 So are you okay with \"alleges\" there, Mr. Everdell?\n3 MR. EVERDELL: Well, let me see about that.\n4 Are we talking just about the overt acts with respect\n5 to Jane or are we talking about with Annie as well? Because\n6 the overt act with respect to Annie is, she's saying she's\n7 under the age of 18, but the age of consent there is 16, so --\n8 and Kate -- there are a few issues here, so I'll just lay them\n9 out.\n10 The instruction with Annie is, you know, there's the\n11 age of consent issue with Annie. But skipping to Kate, which\n12 is No. 4, on line 18, I don't think that should be in there at\n13 all because that invites them to base an overt act and convict\n14 the defendant based on Kate's testimony, which the Court has\n15 already instructed that the jury can't. So, I mean, if they\n16 found that this element was satisfied solely with Kate's\n17 testimony, that would be an improper conviction. So that\n18 shouldn't be included.\n19 MR. ROHRBACH: Insofar as we're no longer following\n20 the exact text of the indictment, the government would be fine\n21 with deleting the overt act relevant to Kate for the reason\n22 Mr. Everdell stated.\n23 THE COURT: Okay. All right.\n24 MR. EVERDELL: All right. So then I think we could\n25 probably say with respect to 1 and 2, which we're talking about\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00016978",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 52 of 95 2790 LCI1MAX1",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 brackets or something.\n2 So are you okay with \"alleges\" there, Mr. Everdell?\n3 MR. EVERDELL: Well, let me see about that.\n4 Are we talking just about the overt acts with respect\n5 to Jane or are we talking about with Annie as well? Because\n6 the overt act with respect to Annie is, she's saying she's\n7 under the age of 18, but the age of consent there is 16, so --\n8 and Kate -- there are a few issues here, so I'll just lay them\n9 out.\n10 The instruction with Annie is, you know, there's the\n11 age of consent issue with Annie. But skipping to Kate, which\n12 is No. 4, on line 18, I don't think that should be in there at\n13 all because that invites them to base an overt act and convict\n14 the defendant based on Kate's testimony, which the Court has\n15 already instructed that the jury can't. So, I mean, if they\n16 found that this element was satisfied solely with Kate's\n17 testimony, that would be an improper conviction. So that\n18 shouldn't be included.\n19 MR. ROHRBACH: Insofar as we're no longer following\n20 the exact text of the indictment, the government would be fine\n21 with deleting the overt act relevant to Kate for the reason\n22 Mr. Everdell stated.\n23 THE COURT: Okay. All right.\n24 MR. EVERDELL: All right. So then I think we could\n25 probably say with respect to 1 and 2, which we're talking about",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00016978",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mr. Everdell",
      "Annie",
      "Kate",
      "Jane",
      "Mr. Rohrbach"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "08/10/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "765",
      "DOJ-OGR-00016978"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a discussion between lawyers and the court about the indictment and overt acts related to a case involving Annie and Kate. The document is well-formatted and easy to read."
}