mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011659.json

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    "page_number": "38",
    "document_number": "739",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 739 Filed 08/10/22 Page 38 of 43 38 LBNAMAXTps 1 Honor. -- New Mexico law, that we would have a substantive 2 violation in addition for this witness. We don't. And in fact 3 I believe the government, bassed on the case law they're 4 citing, the issue they're raising is that there has to be force 5 involved or coercion involved for this to be something illegal. 6 And that's not how they charge it. That's never been an issue 7 in this case. We've litigated that issue quite extensively. 8 So I think it is a correct statement of law to say this is not 9 illegal sexual activity under New Mexico law, and that's what 10 the instruction should reflect to the jury. 11 THE COURT: I think the important point has to be 12 captured in \"as charged by the government and for purposes of 13 establishing the elements that the jury has to consider.\" So I 14 hear your point. I'm going to think about the best way to 15 provide clarity to the jury so that they know what they can and 16 what they can't do with this evidence. 17 MR. EVERDELL: Thank you, your Honor. 18 THE COURT: I'll do my best. And I'll hear from you 19 after I re-propose. 20 Anything else on that? 21 MR. ROHRBACH: No. Thank you, your Honor. 22 THE COURT: Anything else, Mr. Everdell? 23 MR. EVERDELL: No, your Honor. Thank you. 24 THE COURT: All right. So next is just to go over, 25 make sure we're all on the same page -- that's all I have for SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00011659",
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      "content": "1 Honor. -- New Mexico law, that we would have a substantive 2 violation in addition for this witness. We don't. And in fact 3 I believe the government, bassed on the case law they're 4 citing, the issue they're raising is that there has to be force 5 involved or coercion involved for this to be something illegal. 6 And that's not how they charge it. That's never been an issue 7 in this case. We've litigated that issue quite extensively. 8 So I think it is a correct statement of law to say this is not 9 illegal sexual activity under New Mexico law, and that's what 10 the instruction should reflect to the jury. 11 THE COURT: I think the important point has to be 12 captured in \"as charged by the government and for purposes of 13 establishing the elements that the jury has to consider.\" So I 14 hear your point. I'm going to think about the best way to 15 provide clarity to the jury so that they know what they can and 16 what they can't do with this evidence. 17 MR. EVERDELL: Thank you, your Honor. 18 THE COURT: I'll do my best. And I'll hear from you 19 after I re-propose. 20 Anything else on that? 21 MR. ROHRBACH: No. Thank you, your Honor. 22 THE COURT: Anything else, Mr. Everdell? 23 MR. EVERDELL: No, your Honor. Thank you. 24 THE COURT: All right. So next is just to go over, 25 make sure we're all on the same page -- that's all I have for",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00011659",
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  "entities": {
    "people": [
      "Mr. Everdell",
      "Mr. Rohrbach"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [
      "New Mexico"
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    "dates": [
      "08/10/22"
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      "739",
      "DOJ-OGR-00011659"
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