mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00017008.json

{
  "document_metadata": {
    "page_number": "82",
    "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 82 of 95 2820 LCIAMAX2ps\n\n1 THE COURT: Thank you.\n2 MR. ROHRBACH: This is the instruction where the government also has a request, unless Mr. Everdell has anything else on 69.\n3 MR. EVERDELL: I do not.\n4 MR. ROHRBACH: Here the government would request that the Court include the traditional \"government is not on trial\" sentence.\n5 THE COURT: That I didn't permit.\n6 MR. ROHRBACH: I saw that, your Honor. We just wanted to raise it with your Honor again. Our view is that it's something the defense put in issue in their -- came very close to the line of putting in issue in their opening and has been a theme of the defense case so far, and we assume they will come close to the line but hopefully not cross the line in their defense summation. And in light of that, it is an instruction that the circuit has said is appropriate. And so we think, in anticipation of what we expect in the defense's summation, we think it is an appropriate inclusion in this instruction.\n7 MR. EVERDELL: Your Honor, I don't think there's any need to anticipate. If there's an issue about what we say, we're going to be very careful about the Court's ruling. We're going to do our level best to make sure we stay within the four corners of the ruling. But I think this instruction as written is appropriate. I suppose the government, if they want to\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00017008",
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      "content": "Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 82 of 95 2820 LCIAMAX2ps",
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    {
      "type": "printed",
      "content": "1 THE COURT: Thank you.\n2 MR. ROHRBACH: This is the instruction where the government also has a request, unless Mr. Everdell has anything else on 69.\n3 MR. EVERDELL: I do not.\n4 MR. ROHRBACH: Here the government would request that the Court include the traditional \"government is not on trial\" sentence.\n5 THE COURT: That I didn't permit.\n6 MR. ROHRBACH: I saw that, your Honor. We just wanted to raise it with your Honor again. Our view is that it's something the defense put in issue in their -- came very close to the line of putting in issue in their opening and has been a theme of the defense case so far, and we assume they will come close to the line but hopefully not cross the line in their defense summation. And in light of that, it is an instruction that the circuit has said is appropriate. And so we think, in anticipation of what we expect in the defense's summation, we think it is an appropriate inclusion in this instruction.\n7 MR. EVERDELL: Your Honor, I don't think there's any need to anticipate. If there's an issue about what we say, we're going to be very careful about the Court's ruling. We're going to do our level best to make sure we stay within the four corners of the ruling. But I think this instruction as written is appropriate. I suppose the government, if they want to",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00017008",
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  ],
  "entities": {
    "people": [
      "MR. ROHRBACH",
      "MR. EVERDELL"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "765",
      "DOJ-OGR-00017008"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a discussion between the court, Mr. Rohrbach, and Mr. Everdell about a specific instruction. The document is well-formatted and easy to read."
}