mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011721.json

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    "page_number": "56",
    "document_number": "741",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 741 Filed 08/10/22 Page 56 of 106\nLBTVMAX3 Opening - Ms. Sternheim\n1 MR. PAGLIUCA: Correct.\n2 MS. MOE: Your Honor, what Ms. Sternheim said in the opening was that the jury would learn that these women had been manipulated by their attorneys which cultivated their stories.\n3 The factual proffer about the basis for that is the lawyers were sitting in the room while they interviewed them. There is no connection between what's been proffered to this jury and what we are hearing now from defense counsel. The fact that there is an email between a lawyer and a prosecutor suggesting topics about an interview is a separate matter, but certainly wouldn't support the argument that they themselves had manipulated their clients and cultivated the stories. That is an entirely separate matter, your Honor.\n4 THE COURT: I think the inference is available from -- cultivating, so I'm going to allow that. It's unclear to me what evidence will go to it, but the proffer now is that it's not based on anticipated testimony to be elicited from the attorneys, but it's based on nonprivileged communications between the attorneys and the government. And so beyond that, I'm going to let the argument be made, unless the government's position is there is no evidence available from which the inference of manipulation by the attorneys could be made.\n5 MS. MOE: Yes, your Honor.\n6 The only evidence that defense counsel has proffered is an email between an attorney and a prosecutor suggesting\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "type": "printed",
      "content": "LBTVMAX3 Opening - Ms. Sternheim",
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      "content": "1 MR. PAGLIUCA: Correct.\n2 MS. MOE: Your Honor, what Ms. Sternheim said in the opening was that the jury would learn that these women had been manipulated by their attorneys which cultivated their stories.\n3 The factual proffer about the basis for that is the lawyers were sitting in the room while they interviewed them. There is no connection between what's been proffered to this jury and what we are hearing now from defense counsel. The fact that there is an email between a lawyer and a prosecutor suggesting topics about an interview is a separate matter, but certainly wouldn't support the argument that they themselves had manipulated their clients and cultivated the stories. That is an entirely separate matter, your Honor.\n4 THE COURT: I think the inference is available from -- cultivating, so I'm going to allow that. It's unclear to me what evidence will go to it, but the proffer now is that it's not based on anticipated testimony to be elicited from the attorneys, but it's based on nonprivileged communications between the attorneys and the government. And so beyond that, I'm going to let the argument be made, unless the government's position is there is no evidence available from which the inference of manipulation by the attorneys could be made.\n5 MS. MOE: Yes, your Honor.\n6 The only evidence that defense counsel has proffered is an email between an attorney and a prosecutor suggesting",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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    "people": [
      "Ms. Sternheim",
      "MR. PAGLIUCA",
      "MS. MOE"
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      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
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