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- "page_number": "18",
- "document_number": "212-2",
- "date": "04/16/21",
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- "full_text": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 18 of 30\nApp.-0821\n\nG4LMGIUC 17\n1 things that happened prior to her time with them. Your Honor,\n2 we do object to the production of that material.\n3 THE COURT: The flashback allegation.\n4 MS. McCAWLEY: I think what she may be referring to, I\n5 have not heard that term used, I think what she may be\n6 referring to was the fact that this is a defamation claim and\n7 the person who defamed my client was also an abuser, we allege.\n8 So when she is defamed by the person who abused her and that\n9 abuser is calling her a liar, that caused her significant\n10 emotional distress. It's different than if some other\n11 individual that she had not had contact with called her a liar.\n12 When she is talking about a flashback, maybe that's what she is\n13 referring to, but we don't have the word flashback anywhere in\n14 our complaint.\n15 THE COURT: No. I made that up.\n16 There will be no claim by the plaintiff that the\n17 defamation caused her distress by making her aware or as a\n18 result of the prior sexual abuse.\n19 MS. McCAWLEY: The sexual abuse by the defendants?\n20 THE COURT: No.\n21 MS. McCAWLEY: Sexual abuse by others.\n22 THE COURT: Yes.\n23 MS. McCAWLEY: No. Sexual abuse that relates to the\n24 Epstein period, yes.\n25 THE COURT: That I understand.\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00003820",
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- "content": "App.-0821",
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- "content": "1 things that happened prior to her time with them. Your Honor,\n2 we do object to the production of that material.\n3 THE COURT: The flashback allegation.\n4 MS. McCAWLEY: I think what she may be referring to, I\n5 have not heard that term used, I think what she may be\n6 referring to was the fact that this is a defamation claim and\n7 the person who defamed my client was also an abuser, we allege.\n8 So when she is defamed by the person who abused her and that\n9 abuser is calling her a liar, that caused her significant\n10 emotional distress. It's different than if some other\n11 individual that she had not had contact with called her a liar.\n12 When she is talking about a flashback, maybe that's what she is\n13 referring to, but we don't have the word flashback anywhere in\n14 our complaint.\n15 THE COURT: No. I made that up.\n16 There will be no claim by the plaintiff that the\n17 defamation caused her distress by making her aware or as a\n18 result of the prior sexual abuse.\n19 MS. McCAWLEY: The sexual abuse by the defendants?\n20 THE COURT: No.\n21 MS. McCAWLEY: Sexual abuse by others.\n22 THE COURT: Yes.\n23 MS. McCAWLEY: No. Sexual abuse that relates to the\n24 Epstein period, yes.\n25 THE COURT: That I understand.",
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- "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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- "content": "DOJ-OGR-00003820",
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- "people": [
- "MS. McCAWLEY"
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- "SOUTHERN DISTRICT REPORTERS, P.C."
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- "dates": [
- "04/16/21"
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- "1:20-cr-00330-PAE",
- "212-2",
- "App.-0821",
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