mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011722.json

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    "page_number": "57",
    "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 57 of 106 61 LBTVMAX3 Opening - Ms. Sternheim topics to ask the client about. That certainly couldn't be a good-faith basis to suggest to this jury that there will be evidence before them at this trial; that these were more manipulated by their attorneys who cultivated their specific stories told to the government. We think that's inappropriate, your Honor. THE COURT: I'm going to overrule it at the opening stage. I did not preclude the line of argumentation; I wasn't asked to preclude the line of argumentation. You raised the prospect -- you did certainly and I appreciate it, raise the prospect related to a subpoena of a witness's attorney, which I agree with the government is entirely unclear to me how that would be able -- but if the proffers that it's based on existing nonprivileged information from which the jury could infer that these attorneys structured in some way the questions that were asked, I think the line is I don't think you have any basis to say that the attorneys told the witnesses what to say. What evidence are you going to put in that shows the attorneys told the witnesses what to say? MR. PAGLIUCA: Well, so we back up a little bit, your Honor. We have in 2008 -- I'll use Carolyn as the example -- answers to interrogatories that are detailed that do not include Ms. Maxwell; deposition testimony that is detailed but does not include Ms. Maxwell; a 91-page complaint detailed, but does not include Ms. Maxwell. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00011722",
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      "content": "Case 1:20-cr-00330-PAE Document 741 Filed 08/10/22 Page 57 of 106 61 LBTVMAX3 Opening - Ms. Sternheim",
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      "content": "topics to ask the client about. That certainly couldn't be a good-faith basis to suggest to this jury that there will be evidence before them at this trial; that these were more manipulated by their attorneys who cultivated their specific stories told to the government. We think that's inappropriate, your Honor.",
      "position": "top"
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    {
      "type": "printed",
      "content": "THE COURT: I'm going to overrule it at the opening stage. I did not preclude the line of argumentation; I wasn't asked to preclude the line of argumentation. You raised the prospect -- you did certainly and I appreciate it, raise the prospect related to a subpoena of a witness's attorney, which I agree with the government is entirely unclear to me how that would be able -- but if the proffers that it's based on existing nonprivileged information from which the jury could infer that these attorneys structured in some way the questions that were asked, I think the line is I don't think you have any basis to say that the attorneys told the witnesses what to say. What evidence are you going to put in that shows the attorneys told the witnesses what to say?",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "MR. PAGLIUCA: Well, so we back up a little bit, your Honor. We have in 2008 -- I'll use Carolyn as the example -- answers to interrogatories that are detailed that do not include Ms. Maxwell; deposition testimony that is detailed but does not include Ms. Maxwell; a 91-page complaint detailed, but does not include Ms. Maxwell.",
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011722",
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  "entities": {
    "people": [
      "Ms. Sternheim",
      "Carolyn",
      "Ms. Maxwell",
      "MR. PAGLIUCA"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22",
      "2008"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "741",
      "DOJ-OGR-00011722"
    ]
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}