mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00007175.json

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    "page_number": "124",
    "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 124 of 127 124 LB15max4\n\n1 THE COURT: Thank you.\n2 Can I ask the government, if you have a substantial\n3 production, let's say over 50 pages of documents to review, can\n4 the government have those hand-delivered to the facility?\n5 MS. MOE: No, your Honor.\n6 Respectfully, that is extremely resource intensive, it\n7 requires asking either a member of the prosecution team or\n8 their colleagues who are also working on cases to, instead of\n9 pursuing law enforcement activities or preparing for trial,\n10 spend the day driving to the MDC to hand deliver a drive to the\n11 defendant personally which is a remedy that I'm not aware of\n12 being implemented in any other case and would be sort of an\n13 extraordinary step for this defendant that would be out of step\n14 with the ordinary practice.\n15 THE COURT: We are a month away from trial but if we\n16 are a few days away from trial and suddenly the government has\n17 a substantial production of material for some reason, 50 pages,\n18 a hundred pages, would the government take those steps?\n19 MS. MOE: Your Honor, without having a sense of what\n20 those materials are, what their sensitivities are, whether it\n21 is sort of a relevant matter that we are producing in an\n22 abundance of caution or something that is sensitive that is\n23 urgent that is hard to troubleshoot that issue in advance but\n24 we are mindful of Court's concern and that, even as we approach\n25 trial, that the issue of timing is of particular concern and so\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00007175",
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      "content": "1 THE COURT: Thank you.\n2 Can I ask the government, if you have a substantial\n3 production, let's say over 50 pages of documents to review, can\n4 the government have those hand-delivered to the facility?\n5 MS. MOE: No, your Honor.\n6 Respectfully, that is extremely resource intensive, it\n7 requires asking either a member of the prosecution team or\n8 their colleagues who are also working on cases to, instead of\n9 pursuing law enforcement activities or preparing for trial,\n10 spend the day driving to the MDC to hand deliver a drive to the\n11 defendant personally which is a remedy that I'm not aware of\n12 being implemented in any other case and would be sort of an\n13 extraordinary step for this defendant that would be out of step\n14 with the ordinary practice.\n15 THE COURT: We are a month away from trial but if we\n16 are a few days away from trial and suddenly the government has\n17 a substantial production of material for some reason, 50 pages,\n18 a hundred pages, would the government take those steps?\n19 MS. MOE: Your Honor, without having a sense of what\n20 those materials are, what their sensitivities are, whether it\n21 is sort of a relevant matter that we are producing in an\n22 abundance of caution or something that is sensitive that is\n23 urgent that is hard to troubleshoot that issue in advance but\n24 we are mindful of Court's concern and that, even as we approach\n25 trial, that the issue of timing is of particular concern and so",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "DOJ-OGR-00007175",
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    "people": [
      "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-00007175"
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}