mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00007098.json

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    "page_number": "47",
    "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 47 of 127 47\nfor that reason, we would ask that the defense be precluded from opening on this issue or otherwise raising issues related to the credibility of individuals who would not be testifying at this trial including not only non-testifying victims but also attorneys.\nMS. MENNINGER: Your Honor, even the statement \"a non-testifying victim\" is very loaded because who is going to testify that that person is a victim and on what ground? That's the problem.\nTHE COURT: Well, I wouldn't allow testimony by a witness about a characterization that goes to a legal issue so of course they could testify about observations involving other people. I can imagine instances in which they testify about statements of others not offered for the truth but I wouldn't anticipate the government would attempt to do any of that via any characterization of those individuals that go to legal conclusions relevant to the jury's role.\nDo I have that right, Ms. Moe?\nMS. MOE: Yes, your Honor.\nMS. MENNINGER: It is interesting, because in their offer of proof they actually say that one witness is going to talk about another person being a victim of sexual abuse and that second person isn't going to testify, and the question of whether that person was a victim of sexual abuse would turn on the age at which they were conducting certain activities. And\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00007098",
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      "content": "for that reason, we would ask that the defense be precluded from opening on this issue or otherwise raising issues related to the credibility of individuals who would not be testifying at this trial including not only non-testifying victims but also attorneys.\nMS. MENNINGER: Your Honor, even the statement \"a non-testifying victim\" is very loaded because who is going to testify that that person is a victim and on what ground? That's the problem.\nTHE COURT: Well, I wouldn't allow testimony by a witness about a characterization that goes to a legal issue so of course they could testify about observations involving other people. I can imagine instances in which they testify about statements of others not offered for the truth but I wouldn't anticipate the government would attempt to do any of that via any characterization of those individuals that go to legal conclusions relevant to the jury's role.\nDo I have that right, Ms. Moe?\nMS. MOE: Yes, your Honor.\nMS. MENNINGER: It is interesting, because in their offer of proof they actually say that one witness is going to talk about another person being a victim of sexual abuse and that second person isn't going to testify, and the question of whether that person was a victim of sexual abuse would turn on the age at which they were conducting certain activities. And",
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  "entities": {
    "people": [
      "Ms. Menninger",
      "Ms. Moe"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "11/15/21"
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      "1:20-cr-00330-PAE",
      "Document 465",
      "DOJ-OGR-00007098"
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