mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00007131.json

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    "page_number": "80",
    "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 80 of 127\nLB1TMAX3\n1 THE COURT: Who am I hearing from on this one?\n2 MR. EVERDELL: Me, your Honor. Thank you, your Honor.\n3 I think your Honor hit it right on the head right from\n4 the outset, which is if all we had were allegations related to\n5 this particular individual, we would not have a charged crime\n6 here because there was no criminal activity at all.\n7 The only basis for which -- I think the government has\n8 tried to articulate some basis for its relevance as direct\n9 evidence of the charged crimes is her subjective experience of\n10 what happened to her. She was of legal age in every single\n11 jurisdiction where these events allegedly took place. So the\n12 issue of consent, while we may have moral objections to this,\n13 it was entirely legal and the government can't prove otherwise.\n14 So all she's going to testify to, presumably, is how she felt\n15 about those instances, and that is not proof that is probative\n16 of the defendant's guilt of these charges.\n17 Moreover, your Honor, it is quite inflammatory and\n18 misleads the jury to hear when someone feels a certain way what\n19 happened to her, even though legally it doesn't make a\n20 difference, that is going to encourage them to feel sympathy\n21 for her and convict the defendant potentially on a false ground\n22 because there is no illegal conduct here.\n23 Your Honor, I think the government has articulated or\n24 at least tried to articulate at the Court's urging a basis why\n25 this may be direct evidence of the sex trafficking conspiracy.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00007131",
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      "content": "Case 1:20-cr-00330-PAE Document 465 Filed 11/15/21 Page 80 of 127",
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      "content": "LB1TMAX3",
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      "content": "1 THE COURT: Who am I hearing from on this one?\n2 MR. EVERDELL: Me, your Honor. Thank you, your Honor.\n3 I think your Honor hit it right on the head right from\n4 the outset, which is if all we had were allegations related to\n5 this particular individual, we would not have a charged crime\n6 here because there was no criminal activity at all.\n7 The only basis for which -- I think the government has\n8 tried to articulate some basis for its relevance as direct\n9 evidence of the charged crimes is her subjective experience of\n10 what happened to her. She was of legal age in every single\n11 jurisdiction where these events allegedly took place. So the\n12 issue of consent, while we may have moral objections to this,\n13 it was entirely legal and the government can't prove otherwise.\n14 So all she's going to testify to, presumably, is how she felt\n15 about those instances, and that is not proof that is probative\n16 of the defendant's guilt of these charges.\n17 Moreover, your Honor, it is quite inflammatory and\n18 misleads the jury to hear when someone feels a certain way what\n19 happened to her, even though legally it doesn't make a\n20 difference, that is going to encourage them to feel sympathy\n21 for her and convict the defendant potentially on a false ground\n22 because there is no illegal conduct here.\n23 Your Honor, I think the government has articulated or\n24 at least tried to articulate at the Court's urging a basis why\n25 this may be direct evidence of the sex trafficking conspiracy.",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "DOJ-OGR-00007131",
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      "MR. EVERDELL"
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      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "11/15/21"
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      "465",
      "DOJ-OGR-00007131"
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