mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00020858.json

{
  "document_metadata": {
    "page_number": "32",
    "document_number": "58",
    "date": "02/28/2023",
    "document_type": "court transcript",
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  "full_text": "Case 22-1426, Document 58, 02/28/2023, 3475901, Page 32 of 221\nA-232\n3149\nLCSCMAXT\n1 there can be no error in referring the jury to a correct legal instruction. And so no relief is appropriate here.\n2\n3 At bottom your Honor, the jury asked a question and nothing more. There is no reason to speculate about what the jury might be concluding. The jury has been accurately instructed on the law and that's all that's required here.\n4\n5 Going beyond that to speculate about the jury's deliberations and compound speculation upon speculation to send back confusing legal instructions would compound the problem here.\n6\n7 The simple course is exactly the course the Court took yesterday, which is to refer the jury to a thorough and complete accurate legal instruction. There can't be any dispute that the instructions that the Court has given are accurate, and that's all that's required here.\n8\n9 THE COURT: I suppose an additional point, just looking at the -- I mean, the defense's new proposed instruction talks about Count Two, which wasn't asked about.\n10\n11 Also, it has -- so it has three paragraphs. The first one is about Count Two, which wasn't asked about. There is a second paragraph.\n12\n13 And then the third paragraph I think is just wrong, an intent that Jane engaged in sexual activity in any state other than New York cannot form the basis of these elements.\n14\n15 That would suggest it may have no relevance. This is the same discussion we've had a couple of times, Mr. Everdell.\n16\n17 Sexual activity with respect to Jane in New Mexico under the age of 17\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "Case 22-1426, Document 58, 02/28/2023, 3475901, Page 32 of 221",
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      "content": "A-232",
      "position": "header"
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    {
      "type": "printed",
      "content": "3149\nLCSCMAXT\n1 there can be no error in referring the jury to a correct legal instruction. And so no relief is appropriate here.\n2\n3 At bottom your Honor, the jury asked a question and nothing more. There is no reason to speculate about what the jury might be concluding. The jury has been accurately instructed on the law and that's all that's required here.\n4\n5 Going beyond that to speculate about the jury's deliberations and compound speculation upon speculation to send back confusing legal instructions would compound the problem here.\n6\n7 The simple course is exactly the course the Court took yesterday, which is to refer the jury to a thorough and complete accurate legal instruction. There can't be any dispute that the instructions that the Court has given are accurate, and that's all that's required here.\n8\n9 THE COURT: I suppose an additional point, just looking at the -- I mean, the defense's new proposed instruction talks about Count Two, which wasn't asked about.\n10\n11 Also, it has -- so it has three paragraphs. The first one is about Count Two, which wasn't asked about. There is a second paragraph.\n12\n13 And then the third paragraph I think is just wrong, an intent that Jane engaged in sexual activity in any state other than New York cannot form the basis of these elements.\n14\n15 That would suggest it may have no relevance. This is the same discussion we've had a couple of times, Mr. Everdell.\n16\n17 Sexual activity with respect to Jane in New Mexico under the age of 17",
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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  ],
  "entities": {
    "people": [
      "Jane",
      "Mr. Everdell"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "New York",
      "New Mexico"
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    "dates": [
      "02/28/2023"
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    "reference_numbers": [
      "Case 22-1426",
      "Document 58",
      "3475901",
      "Page 32 of 221",
      "A-232",
      "3149"
    ]
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}