mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00016168.json

{
  "document_metadata": {
    "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-AJN Document 741 Filed 08/10/22 Page 58 of 106\nLBTVMAX3 Opening - Ms. Sternheim\n1 It is only after years and after the fund is open that\n2 we then have this witness coming forward in conjunction with\n3 this email that I'm talking about that we've referenced in\n4 papers to the Court. So, for example, Mr. Scarola, who is the\n5 lawyer on this topic, wrote all the answers to interrogatories\n6 and were signed by the client. Then we fast forward, and we\n7 have all this information that's being provided in 2020 which\n8 is not present in 2008.\n9 First of all, all the answers to interrogatories are\n10 not privileged. The communications in the complaint are not\n11 privileged. The lack of information about our client in that\n12 complaint can be inferred that after that is when all this\n13 comes up, because we are seeking money from the victim\n14 compensation fund and we are using the government as part and\n15 parcel of that to buttress our claim to the fund.\n16 MS. COMEY: Your Honor, as an initial matter, it's not\n17 factually accurate that the deposition is --\n18 THE COURT: Okay. So these are arguments you're going\n19 to make to the jury. It's not -- the contention is that the\n20 story has changed and what happened in between was the\n21 involvement of civil lawyers. I have no idea what the evidence\n22 exactly will show with that, and it sounds like there are going\n23 to be arguments to be made on both sides, but that's not based\n24 on privileged testimony. And I have a proffer that the story\n25 has changed over time and what intervened between civil\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00016168",
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      "content": "Case 1:20-cr-00330-AJN Document 741 Filed 08/10/22 Page 58 of 106",
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    {
      "type": "printed",
      "content": "LBTVMAX3 Opening - Ms. Sternheim",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 It is only after years and after the fund is open that\n2 we then have this witness coming forward in conjunction with\n3 this email that I'm talking about that we've referenced in\n4 papers to the Court. So, for example, Mr. Scarola, who is the\n5 lawyer on this topic, wrote all the answers to interrogatories\n6 and were signed by the client. Then we fast forward, and we\n7 have all this information that's being provided in 2020 which\n8 is not present in 2008.\n9 First of all, all the answers to interrogatories are\n10 not privileged. The communications in the complaint are not\n11 privileged. The lack of information about our client in that\n12 complaint can be inferred that after that is when all this\n13 comes up, because we are seeking money from the victim\n14 compensation fund and we are using the government as part and\n15 parcel of that to buttress our claim to the fund.\n16 MS. COMEY: Your Honor, as an initial matter, it's not\n17 factually accurate that the deposition is --\n18 THE COURT: Okay. So these are arguments you're going\n19 to make to the jury. It's not -- the contention is that the\n20 story has changed and what happened in between was the\n21 involvement of civil lawyers. I have no idea what the evidence\n22 exactly will show with that, and it sounds like there are going\n23 to be arguments to be made on both sides, but that's not based\n24 on privileged testimony. And I have a proffer that the story\n25 has changed over time and what intervened between civil",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00016168",
      "position": "footer"
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  "entities": {
    "people": [
      "Ms. Sternheim",
      "Mr. Scarola",
      "MS. COMEY"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "08/10/22",
      "2008",
      "2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "741",
      "DOJ-OGR-00016168"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}