mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011720.json

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    "page_number": "55",
    "document_number": "741",
    "date": "08/10/2022",
    "document_type": "Court Transcript",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 741 Filed 08/10/22 Page 55 of 106 59 LBTVMAX3 Opening - Ms. Sternheim\n\n1 THE COURT: So tell me what you're going to do.\n2 You're going to call -- so a witness will testify, and then you're going to call that witness's attorney. What is it that you're going to do? What evidence are you going to --\n5 MR. PAGLIUCA: The lawyers are in proffers, your honor, and the witness is in the proffer. The witness can talk about what the lawyer said to the government in the proffer. The lawyers have emails to the government lawyers about what their clients will or won't say. There's an email from Mr. Scarola to the government in which Mr. Scarola suggests ten topics for the interview with Carolyn. Those are not privileged conversations.\n13 THE COURT: Sorry. Just to clarify, you're saying this is not what you just said, the cultivating of the stories by these lawyers; you do not intend to get that by calling any of these lawyers as witnesses.\n17 MR. PAGLIUCA: Not unless we brief it and you give us permission to do that.\n19 THE COURT: But instead, it's based on communications between the lawyers and the government?\n21 MR. PAGLIUCA: Correct.\n22 THE COURT: And email.\n23 MR. PAGLIUCA: And in proffers.\n24 THE COURT: And in proffers in which the government was present.\n25 was present.\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "Case 1:20-cr-00330-PAE Document 741 Filed 08/10/22 Page 55 of 106 59 LBTVMAX3 Opening - Ms. Sternheim",
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      "type": "printed",
      "content": "1 THE COURT: So tell me what you're going to do.\n2 You're going to call -- so a witness will testify, and then you're going to call that witness's attorney. What is it that you're going to do? What evidence are you going to --\n5 MR. PAGLIUCA: The lawyers are in proffers, your honor, and the witness is in the proffer. The witness can talk about what the lawyer said to the government in the proffer. The lawyers have emails to the government lawyers about what their clients will or won't say. There's an email from Mr. Scarola to the government in which Mr. Scarola suggests ten topics for the interview with Carolyn. Those are not privileged conversations.\n13 THE COURT: Sorry. Just to clarify, you're saying this is not what you just said, the cultivating of the stories by these lawyers; you do not intend to get that by calling any of these lawyers as witnesses.\n17 MR. PAGLIUCA: Not unless we brief it and you give us permission to do that.\n19 THE COURT: But instead, it's based on communications between the lawyers and the government?\n21 MR. PAGLIUCA: Correct.\n22 THE COURT: And email.\n23 MR. PAGLIUCA: And in proffers.\n24 THE COURT: And in proffers in which the government was present.\n25 was present.",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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  "entities": {
    "people": [
      "Ms. Sternheim",
      "MR. PAGLIUCA",
      "Mr. Scarola",
      "Carolyn"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "08/10/2022"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "741"
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  "additional_notes": "The document appears to be a court transcript with clear and legible text. There are no visible redactions or damage."
}