mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00016164.json

{
  "document_metadata": {
    "page_number": "54",
    "document_number": "741",
    "date": "08/10/22",
    "document_type": "Court Transcript",
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  "full_text": "Case 1:20-cr-00330-AJN Document 741 Filed 08/10/22 Page 54 of 106\nLBTVMAX3 Opening - Ms. Sternheim\n1 certainly their attorneys couldn't be called as witnesses to\n2 talk about that. Beyond that, I can't imagine a good-faith\n3 basis to proffer that evidence to come before this jury about\n4 that.\n5 MS. STERNHEIM: Judge, the government well knows that\n6 the lawyers for these people sat in their offices through\n7 proffer sessions. If nothing else, they are witnesses to what\n8 went on in that room. They also separately were in\n9 communication with the government providing information to the\n10 government; and the government, in turn, was helping them build\n11 their cases, their civil cases, and their cases for settlement.\n12 So there is a good-faith basis to raise these things.\n13 THE COURT: I had said clearly, since it's unclear,\n14 how you can call lawyers for witnesses in this case as\n15 witnesses themselves; that you wouldn't do so unless you\n16 briefed it specifically. You have not done that. So you may\n17 not refer to that testimony that you somehow anticipate getting\n18 in, although I don't know how you will in your opening. You\n19 may not. I was very clear that before that would happen, you\n20 would have to brief it. I haven't seen any briefing, so you\n21 may not reference it.\n22 MS. STERNHEIM: But, Judge, may I just say there's no\n23 dispute that if a witness to a proffer has information that may\n24 be a conflict with the testimony here, there is no privilege to\n25 that.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "Case 1:20-cr-00330-AJN Document 741 Filed 08/10/22 Page 54 of 106",
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    {
      "type": "printed",
      "content": "LBTVMAX3 Opening - Ms. Sternheim",
      "position": "header"
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      "type": "printed",
      "content": "1 certainly their attorneys couldn't be called as witnesses to\n2 talk about that. Beyond that, I can't imagine a good-faith\n3 basis to proffer that evidence to come before this jury about\n4 that.\n5 MS. STERNHEIM: Judge, the government well knows that\n6 the lawyers for these people sat in their offices through\n7 proffer sessions. If nothing else, they are witnesses to what\n8 went on in that room. They also separately were in\n9 communication with the government providing information to the\n10 government; and the government, in turn, was helping them build\n11 their cases, their civil cases, and their cases for settlement.\n12 So there is a good-faith basis to raise these things.\n13 THE COURT: I had said clearly, since it's unclear,\n14 how you can call lawyers for witnesses in this case as\n15 witnesses themselves; that you wouldn't do so unless you\n16 briefed it specifically. You have not done that. So you may\n17 not refer to that testimony that you somehow anticipate getting\n18 in, although I don't know how you will in your opening. You\n19 may not. I was very clear that before that would happen, you\n20 would have to brief it. I haven't seen any briefing, so you\n21 may not reference it.\n22 MS. STERNHEIM: But, Judge, may I just say there's no\n23 dispute that if a witness to a proffer has information that may\n24 be a conflict with the testimony here, there is no privilege to\n25 that.",
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
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  "entities": {
    "people": [
      "Ms. Sternheim"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "08/10/22"
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    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "741"
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  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}