mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009501.json

{
  "document_metadata": {
    "page_number": "82",
    "document_number": "1:20-cr-00336-PAE",
    "date": "08/24/22",
    "document_type": "court document",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00336-PAE Document 61 Filed 08/24/22 Page 82 of 117\nA-5925\n23\nCAC3PARC has stated that you can find that where there has been a split verdict, as is the case with Mr. Parse, that is evidence of a lack of prejudice. We had argued in the original motion for new trial and we renew that as well.\nFinally, your Honor, with regard to the letter of Catherine Conrad to the government which was referenced in the defendant's briefing, she talked about their discussions and deliberations with regard to David Parse. And interestingly what she also said, which was not mentioned when Mr. Shechtman in his brief, was that that struggle ended when they asked the Court to reread the definitions of wilfully and knowingly. Different states for different counts.\nMR. SHECHTMAN: Well, I'll wait. I apologize to the Court.\nMS. DAVIS: And interestingly, their verdict exactly tracked that difference between wilfully, this was required in the conspiracy count and for the tax evasion counts, and knowingly which was really the mens rea relating to other ones. So you might say that they had a struggle.\nTo the extent we can even be considering that letter at all because of Rule 606(b), but I think it's quite clear that they made a deliberate and informed decision about making a distinction drawn on the evidence as apply to the law. Thank you.\nTHE COURT: Thank you, Ms. Davis.\nTHE SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00009501",
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      "content": "Case 1:20-cr-00336-PAE Document 61 Filed 08/24/22 Page 82 of 117",
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      "content": "A-5925",
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      "type": "printed",
      "content": "23\nCAC3PARC has stated that you can find that where there has been a split verdict, as is the case with Mr. Parse, that is evidence of a lack of prejudice. We had argued in the original motion for new trial and we renew that as well.\nFinally, your Honor, with regard to the letter of Catherine Conrad to the government which was referenced in the defendant's briefing, she talked about their discussions and deliberations with regard to David Parse. And interestingly what she also said, which was not mentioned when Mr. Shechtman in his brief, was that that struggle ended when they asked the Court to reread the definitions of wilfully and knowingly. Different states for different counts.\nMR. SHECHTMAN: Well, I'll wait. I apologize to the Court.\nMS. DAVIS: And interestingly, their verdict exactly tracked that difference between wilfully, this was required in the conspiracy count and for the tax evasion counts, and knowingly which was really the mens rea relating to other ones. So you might say that they had a struggle.\nTo the extent we can even be considering that letter at all because of Rule 606(b), but I think it's quite clear that they made a deliberate and informed decision about making a distinction drawn on the evidence as apply to the law. Thank you.",
      "position": "main"
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    {
      "type": "printed",
      "content": "THE COURT: Thank you, Ms. Davis.",
      "position": "main"
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    {
      "type": "printed",
      "content": "THE SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "type": "printed",
      "content": "DOJ-OGR-00009501",
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  "entities": {
    "people": [
      "Catherine Conrad",
      "David Parse",
      "Mr. Parse",
      "Mr. Shechtman",
      "Ms. Davis"
    ],
    "organizations": [
      "THE SOUTHERN DISTRICT REPORTERS, P.C.",
      "DOJ"
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    "locations": [],
    "dates": [
      "08/24/22"
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    "reference_numbers": [
      "1:20-cr-00336-PAE",
      "A-5925",
      "DOJ-OGR-00009501"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible text. There are no visible redactions or damage."
}