mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009496.json

{
  "document_metadata": {
    "page_number": "73",
    "document_number": "6168/20",
    "date": "08/24/22",
    "document_type": "Court Document",
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  "full_text": "Case 1:20-cr-00336-PAE Document 6168/20 Filed 08/24/22 Page 73 of 117\nA-5920\n\n18\n\nCAC3PARC\n1 which I think is very significant. And it is significant in\n2 part because I think if we can say anything, that we all know\n3 based on the Brune & Richard's defense of Mr. Parse, that if\n4 they had any actual and real concern about a suspended attorney\n5 being on this jury, if they really thought that was not in\n6 their client's interest, you know, we all know that they would\n7 have brought it to the Court's attention during voir dire. And\n8 if not at voir dire, then after the results of the Theresa\n9 Trzskoma investigation.\n10 This is absolutely a situation where the Brune &\n11 Richard lawyers, on May 12, after the investigation that they\n12 had, they looked at all the alternatives. We know because\n13 Laurie Edelstein testified at the hearing, they considered the\n14 three possible alternatives. They considered whether or not\n15 they should do more investigation, and Susan Brune said no.\n16 They considered whether or not they should bring it to the\n17 Court's attention, and they said no. So they decided to do\n18 nothing. And it is that conscious and deliberate choice that\n19 we believe means that they made a strategic choice that cannot\n20 form the basis of ineffective assistance of counsel.\n21 How do we know in the government's view that this\n22 indeed was a tactical choice? As this Court just pointed out\n23 with regard to the questioning of Mr. Shechtman, they did not\n24 bring that knowledge to the attention of the Court either in\n25 the brief, where they made it appear as if they first learned\nthe brief, where they made it appear as if they first learned\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "Case 1:20-cr-00336-PAE Document 6168/20 Filed 08/24/22 Page 73 of 117",
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    {
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      "content": "A-5920",
      "position": "header"
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    {
      "type": "printed",
      "content": "18\n\nCAC3PARC\n1 which I think is very significant. And it is significant in\n2 part because I think if we can say anything, that we all know\n3 based on the Brune & Richard's defense of Mr. Parse, that if\n4 they had any actual and real concern about a suspended attorney\n5 being on this jury, if they really thought that was not in\n6 their client's interest, you know, we all know that they would\n7 have brought it to the Court's attention during voir dire. And\n8 if not at voir dire, then after the results of the Theresa\n9 Trzskoma investigation.\n10 This is absolutely a situation where the Brune &\n11 Richard lawyers, on May 12, after the investigation that they\n12 had, they looked at all the alternatives. We know because\n13 Laurie Edelstein testified at the hearing, they considered the\n14 three possible alternatives. They considered whether or not\n15 they should do more investigation, and Susan Brune said no.\n16 They considered whether or not they should bring it to the\n17 Court's attention, and they said no. So they decided to do\n18 nothing. And it is that conscious and deliberate choice that\n19 we believe means that they made a strategic choice that cannot\n20 form the basis of ineffective assistance of counsel.\n21 How do we know in the government's view that this\n22 indeed was a tactical choice? As this Court just pointed out\n23 with regard to the questioning of Mr. Shechtman, they did not\n24 bring that knowledge to the attention of the Court either in\n25 the brief, where they made it appear as if they first learned",
      "position": "main"
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Mr. Parse",
      "Theresa Trzskoma",
      "Laurie Edelstein",
      "Susan Brune",
      "Mr. Shechtman"
    ],
    "organizations": [
      "Brune & Richard",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "May 12",
      "08/24/22"
    ],
    "reference_numbers": [
      "1:20-cr-00336-PAE",
      "6168/20",
      "A-5920"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and easy to read."
}