mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011723.json

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    "page_number": "58",
    "document_number": "741",
    "date": "08/10/22",
    "document_type": "Court Transcript",
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  "full_text": "Case 1:20-cr-00330-PAE Document 741 Filed 08/10/22 Page 58 of 106 62 LBTVMAX3 Opening - Ms. Sternheim It is only after years and after the fund is open that we then have this witness coming forward in conjunction with this email that I'm talking about that we've referenced in papers to the Court. So, for example, Mr. Scarola, who is the lawyer on this topic, wrote all the answers to interrogatories and were signed by the client. Then we fast forward, and we have all this information that's being provided in 2020 which is not present in 2008. First of all, all the answers to interrogatories are not privileged. The communications in the complaint are not privileged. The lack of information about our client in that complaint can be inferred that after that is when all this comes up, because we are seeking money from the victim compensation fund and we are using the government as part and parcel of that to buttress our claim to the fund. MS. COMEY: Your Honor, as an initial matter, it's not factually accurate that the deposition is -- THE COURT: Okay. So these are arguments you're going to make to the jury. It's not -- the contention is that the story has changed and what happened in between was the involvement of civil lawyers. I have no idea what the evidence exactly will show with that, and it sounds like there are going to be arguments to be made on both sides, but that's not based on privileged testimony. And I have a proffer that the story has changed over time and what intervened between civil SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00011723",
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      "type": "printed",
      "content": "It is only after years and after the fund is open that we then have this witness coming forward in conjunction with this email that I'm talking about that we've referenced in papers to the Court. So, for example, Mr. Scarola, who is the lawyer on this topic, wrote all the answers to interrogatories and were signed by the client. Then we fast forward, and we have all this information that's being provided in 2020 which is not present in 2008. First of all, all the answers to interrogatories are not privileged. The communications in the complaint are not privileged. The lack of information about our client in that complaint can be inferred that after that is when all this comes up, because we are seeking money from the victim compensation fund and we are using the government as part and parcel of that to buttress our claim to the fund. MS. COMEY: Your Honor, as an initial matter, it's not factually accurate that the deposition is -- THE COURT: Okay. So these are arguments you're going to make to the jury. It's not -- the contention is that the story has changed and what happened in between was the involvement of civil lawyers. I have no idea what the evidence exactly will show with that, and it sounds like there are going to be arguments to be made on both sides, but that's not based on privileged testimony. And I have a proffer that the story has changed over time and what intervened between civil",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00011723",
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  "entities": {
    "people": [
      "Ms. Sternheim",
      "Mr. Scarola",
      "MS. COMEY"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "08/10/22",
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      "2020"
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      "1:20-cr-00330-PAE",
      "741",
      "DOJ-OGR-00011723"
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}