mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00012174.json

{
  "document_metadata": {
    "page_number": "154",
    "document_number": "745",
    "date": "08/10/22",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 154 of 264\nLC1VMAX5 Jane - cross\n1 she says no, if a privileged communication with her attorney\n2 would be a proper basis for impeachment.\n3 On that score, if we get to that scenario, this\n4 witness's counsel is in the courtroom. I've conferred with him\n5 about the privilege issue. My understanding is his view is\n6 this is privileged and he'd like to confer with his client\n7 about that. But I think he'd like to be heard on the question\n8 of privilege and waiver. It's not the government's privilege\n9 to hold or waive or speak to; and so we'd ask for him to be\n10 heard on that question.\n11 THE COURT: Well, I guess it still depends what we're\n12 talking about. What is the \"this\" in that sentence?\n13 MS. MODE: It sounds like, your Honor, if defense\n14 counsel plans to impeach this witness about bias by offering a\n15 statement of her attorney to the government, that that\n16 implicates a privilege question. If separately defense counsel\n17 plans to ask this witness just generally --\n18 THE COURT: The statement from the attorney to the\n19 government is not privileged. This is not privileged. The\n20 question goes to her communication with her attorney, that's\n21 where the privilege is.\n22 MS. MODE: Exactly, your Honor.\n23 THE COURT: I'm not yet seeing the connection between\n24 what I -- I don't know what the basis of admissibility would be\n25 with respect to this email that's been handed up, which is a\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00012174",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 745 Filed 08/10/22 Page 154 of 264",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LC1VMAX5 Jane - cross",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 she says no, if a privileged communication with her attorney\n2 would be a proper basis for impeachment.\n3 On that score, if we get to that scenario, this\n4 witness's counsel is in the courtroom. I've conferred with him\n5 about the privilege issue. My understanding is his view is\n6 this is privileged and he'd like to confer with his client\n7 about that. But I think he'd like to be heard on the question\n8 of privilege and waiver. It's not the government's privilege\n9 to hold or waive or speak to; and so we'd ask for him to be\n10 heard on that question.\n11 THE COURT: Well, I guess it still depends what we're\n12 talking about. What is the \"this\" in that sentence?\n13 MS. MODE: It sounds like, your Honor, if defense\n14 counsel plans to impeach this witness about bias by offering a\n15 statement of her attorney to the government, that that\n16 implicates a privilege question. If separately defense counsel\n17 plans to ask this witness just generally --\n18 THE COURT: The statement from the attorney to the\n19 government is not privileged. This is not privileged. The\n20 question goes to her communication with her attorney, that's\n21 where the privilege is.\n22 MS. MODE: Exactly, your Honor.\n23 THE COURT: I'm not yet seeing the connection between\n24 what I -- I don't know what the basis of admissibility would be\n25 with respect to this email that's been handed up, which is a",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00012174",
      "position": "footer"
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  ],
  "entities": {
    "people": [],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "745",
      "DOJ-OGR-00012174"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a discussion about attorney-client privilege. The text is mostly clear, but there may be some minor formatting issues due to the original document's layout."
}