mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00002425.json

{
  "document_metadata": {
    "page_number": "16",
    "document_number": "136",
    "date": "02/04/21",
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  "full_text": "Case 1:20-cr-00330-AJN Document 136 Filed 02/04/21 Page 16 of 27\n\n2. The Second Question: \"List all of the people under the age of 18 that you interacted with at any of Jeffrey's properties?\"\n\nThe second \"question\" was equally improper. First, this is not a question. Rather, it is a demand to do something, make a list. Fed. R. Civ. P. 30(a)(1) limits a deposition to \"oral questions.\" The question was grossly ambiguous: who was \"Jeffrey\"; what were \"Jeffrey's properties;\" to what time frame did the question apply; what was the basis for Ms. Maxwell to determine who may or may not have been \"under the age of 18\"; and what did \"interact with\" mean?\n\nAgain, the Government selectively omits objections, context, and relevant colloquy. This series of questions begins at page 382 of the April 2016 deposition:\n\n[REDACTED TEXT BLOCK]\n\n11\nDOJ-OGR-00002425",
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      "content": "Case 1:20-cr-00330-AJN Document 136 Filed 02/04/21 Page 16 of 27",
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    {
      "type": "printed",
      "content": "2. The Second Question: \"List all of the people under the age of 18 that you interacted with at any of Jeffrey's properties?\"",
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    },
    {
      "type": "printed",
      "content": "The second \"question\" was equally improper. First, this is not a question. Rather, it is a demand to do something, make a list. Fed. R. Civ. P. 30(a)(1) limits a deposition to \"oral questions.\" The question was grossly ambiguous: who was \"Jeffrey\"; what were \"Jeffrey's properties;\" to what time frame did the question apply; what was the basis for Ms. Maxwell to determine who may or may not have been \"under the age of 18\"; and what did \"interact with\" mean?",
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    {
      "type": "printed",
      "content": "Again, the Government selectively omits objections, context, and relevant colloquy. This series of questions begins at page 382 of the April 2016 deposition:",
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      "content": "[REDACTED TEXT BLOCK]",
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      "content": "11",
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      "content": "DOJ-OGR-00002425",
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  "entities": {
    "people": [
      "Jeffrey",
      "Ms. Maxwell"
    ],
    "organizations": [
      "Government"
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    "locations": [],
    "dates": [
      "02/04/21",
      "April 2016"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 136",
      "Page 16 of 27",
      "DOJ-OGR-00002425",
      "382"
    ]
  },
  "additional_notes": "The document contains redactions in the form of blacked-out text blocks. The quality of the document is otherwise clear and legible."
}