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- "page_number": "20",
- "document_number": "212-2",
- "date": "04/16/21",
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- "full_text": "Case 1:20-cr-00330-PAE Document 212-2 Filed 04/16/21 Page 20 of 30\nApp.-0823\n\nG4LMGIUC\n19\n1 review so you are aware of the ongoing investigation. But it\n2 is my view that that needs to be protected.\n3 As you probably know, the history of these cases with\n4 Mr. Epstein, there were a variety of things that went on in\n5 that investigation, so there is reason to keep an investigation\n6 in this situation protected so that they can properly\n7 investigate and move forward with that without being inhibited\n8 by other individuals. Your Honor, I would ask that that remain\n9 protected. It's covered by her very, very broad requests,\n10 which is why we had to lodge those objections. I would\n11 appreciate your Honor considering our arguments with respect to\n12 that issue.\n13 The other things, your Honor, that she has raised is,\n14 for example, she had asked for the Epstein settlement agreement\n15 and that was one of the things that she asked for. We agreed\n16 to produce that if we got the waiver from Mr. Epstein because\n17 we can't produce it without that waiver.\n18 I believe that covers it, your Honor. If you have any\n19 questions, I would be happy to answer them.\n20 THE COURT: Thanks very much.\n21 Thank you all for all the clarification that you've\n22 given me. I much appreciate it.\n23 With respect to the retainers and the dates of\n24 representation, that information will be provided for any\n25 attorney that's listed on the privilege log.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00003822",
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- "content": "App.-0823",
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- "content": "G4LMGIUC\n19\n1 review so you are aware of the ongoing investigation. But it\n2 is my view that that needs to be protected.\n3 As you probably know, the history of these cases with\n4 Mr. Epstein, there were a variety of things that went on in\n5 that investigation, so there is reason to keep an investigation\n6 in this situation protected so that they can properly\n7 investigate and move forward with that without being inhibited\n8 by other individuals. Your Honor, I would ask that that remain\n9 protected. It's covered by her very, very broad requests,\n10 which is why we had to lodge those objections. I would\n11 appreciate your Honor considering our arguments with respect to\n12 that issue.\n13 The other things, your Honor, that she has raised is,\n14 for example, she had asked for the Epstein settlement agreement\n15 and that was one of the things that she asked for. We agreed\n16 to produce that if we got the waiver from Mr. Epstein because\n17 we can't produce it without that waiver.\n18 I believe that covers it, your Honor. If you have any\n19 questions, I would be happy to answer them.\n20 THE COURT: Thanks very much.\n21 Thank you all for all the clarification that you've\n22 given me. I much appreciate it.\n23 With respect to the retainers and the dates of\n24 representation, that information will be provided for any\n25 attorney that's listed on the privilege log.",
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- "type": "printed",
- "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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- "type": "printed",
- "content": "DOJ-OGR-00003822",
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- "entities": {
- "people": [
- "Mr. Epstein"
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- "organizations": [
- "SOUTHERN DISTRICT REPORTERS, P.C."
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- "locations": [],
- "dates": [
- "04/16/21"
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- "reference_numbers": [
- "1:20-cr-00330-PAE",
- "212-2",
- "App.-0823",
- "DOJ-OGR-00003822"
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