mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00007088.json

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    "page_number": "37",
    "document_number": "465",
    "date": "11/15/21",
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  "full_text": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 37 of 127\nLB15MAX2\n1 information including e-mails between the defendant and Jeffrey Epstein. It is difficult for the government to determine in the abstract what the defense might point to, but that night include, for example, a false exculpatory statement. And so the government's view is unless and until there is a proffer from the defense about a specific statement, that the defense should be precluded from offering a statement along those lines in opening statements or otherwise.\n9 THE COURT: Who is taking this one?\n10 MR. PAGLIUCA: Your Honor, good morning. Jeffrey Pagliuca for Ms. Maxwell.\n11 Your Honor, this is a trial time decision. It depends on what witnesses is testifying and whether or not there is a relevant exception to the hearsay rule. I mean, we understand the rules, we will follow the rules, and if the witness testifies and it becomes relevant, we will ask the question. If there is an objection, the Court will resolve the objection.\n18 THE COURT: And you understand you are going to be restrained by what one might say is an asymmetry between the government's ability to use out-of-court statements by the defendant and the defense's inability to do that, absent some other --\n23 MR. PAGLIUCA: Absolutely, your Honor.\n24 THE COURT: OK.\n25 MR. PAGLIUCA: We understand the hearsay rules.\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007088",
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      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 37 of 127",
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      "content": "LB15MAX2",
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    {
      "type": "printed",
      "content": "1 information including e-mails between the defendant and Jeffrey Epstein. It is difficult for the government to determine in the abstract what the defense might point to, but that night include, for example, a false exculpatory statement. And so the government's view is unless and until there is a proffer from the defense about a specific statement, that the defense should be precluded from offering a statement along those lines in opening statements or otherwise.",
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    {
      "type": "printed",
      "content": "9 THE COURT: Who is taking this one?\n10 MR. PAGLIUCA: Your Honor, good morning. Jeffrey Pagliuca for Ms. Maxwell.",
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    {
      "type": "printed",
      "content": "11 Your Honor, this is a trial time decision. It depends on what witnesses is testifying and whether or not there is a relevant exception to the hearsay rule. I mean, we understand the rules, we will follow the rules, and if the witness testifies and it becomes relevant, we will ask the question. If there is an objection, the Court will resolve the objection.",
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    {
      "type": "printed",
      "content": "18 THE COURT: And you understand you are going to be restrained by what one might say is an asymmetry between the government's ability to use out-of-court statements by the defendant and the defense's inability to do that, absent some other --",
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    {
      "type": "printed",
      "content": "23 MR. PAGLIUCA: Absolutely, your Honor.\n24 THE COURT: OK.\n25 MR. PAGLIUCA: We understand the hearsay rules.",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00007088",
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  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Ms. Maxwell",
      "Jeffrey Pagliuca"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "11/15/21"
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      "1:20-cr-00330-PAE",
      "Document 465",
      "DOJ-OGR-00007088"
    ]
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}