mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00016166.json

{
  "document_metadata": {
    "page_number": "56",
    "document_number": "741",
    "date": "08/10/22",
    "document_type": "court transcript",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-AJN Document 741 Filed 08/10/22 Page 56 of 106\nLBTVMAX3 Opening - Ms. Sternheim\n1\nMR. PAGLIUCA: Correct.\n2\nMS. MOE: Your Honor, what Ms. Sternheim said in the\n3\nopening was that the jury would learn that these women had been\n4\nmanipulated by their attorneys which cultivated their stories.\n5\nThe factual proffer about the basis for that is the lawyers\n6\nwere sitting in the room while they interviewed them. There is\n7\nno connection between what's been proffered to this jury and\n8\nwhat we are hearing now from defense counsel. The fact that\n9\nthere is an email between a lawyer and a prosecutor suggesting\n10\ntopics about an interview is a separate matter, but certainly\n11\nwouldn't support the argument that they themselves had\n12\nmanipulated their clients and cultivated the stories. That is\n13\nan entirely separate matter, your Honor.\n14\nTHE COURT: I think the inference is available from --\n15\ncultivating, so I'm going to allow that. It's unclear to me\n16\nwhat evidence will go to it, but the proffer now is that it's\n17\nnot based on anticipated testimony to be elicited from the\n18\nattorneys, but it's based on nonprivileged communications\n19\nbetween the attorneys and the government. And so beyond that,\n20\nI'm going to let the argument be made, unless the government's\n21\nposition is there is no evidence available from which the\n22\ninference of manipulation by the attorneys could be made.\n23\nMS. MOE: Yes, your Honor.\n24\nThe only evidence that defense counsel has proffered\n25\nis an email between an attorney and a prosecutor suggesting\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00016166",
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      "content": "Case 1:20-cr-00330-AJN Document 741 Filed 08/10/22 Page 56 of 106",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LBTVMAX3 Opening - Ms. Sternheim",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1\nMR. PAGLIUCA: Correct.\n2\nMS. MOE: Your Honor, what Ms. Sternheim said in the\n3\nopening was that the jury would learn that these women had been\n4\nmanipulated by their attorneys which cultivated their stories.\n5\nThe factual proffer about the basis for that is the lawyers\n6\nwere sitting in the room while they interviewed them. There is\n7\nno connection between what's been proffered to this jury and\n8\nwhat we are hearing now from defense counsel. The fact that\n9\nthere is an email between a lawyer and a prosecutor suggesting\n10\ntopics about an interview is a separate matter, but certainly\n11\nwouldn't support the argument that they themselves had\n12\nmanipulated their clients and cultivated the stories. That is\n13\nan entirely separate matter, your Honor.\n14\nTHE COURT: I think the inference is available from --\n15\ncultivating, so I'm going to allow that. It's unclear to me\n16\nwhat evidence will go to it, but the proffer now is that it's\n17\nnot based on anticipated testimony to be elicited from the\n18\nattorneys, but it's based on nonprivileged communications\n19\nbetween the attorneys and the government. And so beyond that,\n20\nI'm going to let the argument be made, unless the government's\n21\nposition is there is no evidence available from which the\n22\ninference of manipulation by the attorneys could be made.\n23\nMS. MOE: Yes, your Honor.\n24\nThe only evidence that defense counsel has proffered\n25\nis an email between an attorney and a prosecutor suggesting",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00016166",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Ms. Sternheim",
      "MR. PAGLIUCA",
      "MS. MOE"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "741",
      "DOJ-OGR-00016166"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}