mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009504.json

{
  "document_metadata": {
    "page_number": "85",
    "document_number": "1616620",
    "date": "02/24/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00338-PAE Document 1616620 Filed 02/24/22 Page 85 of 117\nA-5928\n\nCAC3PARC 26\n1 But the real question is, did Mr. Parse know that that was\n2 defrauding the government. Right.\n3 Look, the avalanche of work here was in December. But\n4 the question is, if you made a mistake, like in my example, can\n5 you undo it. And you have to appreciate what the government\n6 has said to you today. It has essentially said if it is a\n7 broker's mistake, like in my hypothetical, then maybe a\n8 reasonable broker could think you could undo it. But if it is\n9 a lawyer's mistake, you can't. And that's a very different\n10 version of the annual accounting rule than I've ever heard\n11 before. Right. And if my hypothetical is one in which a\n12 reasonable broker could think leave it up to the tax lawyers, I\n13 am not sure what happened in this case isn't in that same\n14 category.\n15 We ended up with an argument about the contents of the\n16 note and how your Honor should interpret them to show whether\n17 there was prejudice here. All of this began with the\n18 government saying to us be careful, Rule 606(b) has its limits.\n19 The one thing I know, and the Third Circuit case in Breakiron\n20 is quite good on talking about whether one looks at this\n21 subjectively or objectively, you can't draw inferences from\n22 that juror's note in deciding whether there was prejudice here\n23 for two reasons. One, 606(b) precludes it, and two, that note\n24 was written by Catherine Conrad and I still don't think the\n25 United States wants to be standing up in a court and saying\nUnited States Southern District Reporters, P.C.\n(212) 805-0300",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00338-PAE Document 1616620 Filed 02/24/22 Page 85 of 117",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "A-5928",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "CAC3PARC 26",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 But the real question is, did Mr. Parse know that that was\n2 defrauding the government. Right.\n3 Look, the avalanche of work here was in December. But\n4 the question is, if you made a mistake, like in my example, can\n5 you undo it. And you have to appreciate what the government\n6 has said to you today. It has essentially said if it is a\n7 broker's mistake, like in my hypothetical, then maybe a\n8 reasonable broker could think you could undo it. But if it is\n9 a lawyer's mistake, you can't. And that's a very different\n10 version of the annual accounting rule than I've ever heard\n11 before. Right. And if my hypothetical is one in which a\n12 reasonable broker could think leave it up to the tax lawyers, I\n13 am not sure what happened in this case isn't in that same\n14 category.\n15 We ended up with an argument about the contents of the\n16 note and how your Honor should interpret them to show whether\n17 there was prejudice here. All of this began with the\n18 government saying to us be careful, Rule 606(b) has its limits.\n19 The one thing I know, and the Third Circuit case in Breakiron\n20 is quite good on talking about whether one looks at this\n21 subjectively or objectively, you can't draw inferences from\n22 that juror's note in deciding whether there was prejudice here\n23 for two reasons. One, 606(b) precludes it, and two, that note\n24 was written by Catherine Conrad and I still don't think the\n25 United States wants to be standing up in a court and saying",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "United States Southern District Reporters, P.C.\n(212) 805-0300",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mr. Parse",
      "Catherine Conrad"
    ],
    "organizations": [
      "United States Southern District Reporters, P.C."
    ],
    "locations": [],
    "dates": [
      "December",
      "02/24/22"
    ],
    "reference_numbers": [
      "1:20-cr-00338-PAE",
      "1616620",
      "606(b)"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible text. There are no visible redactions or damage."
}