mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00012945.json

{
  "document_metadata": {
    "page_number": "194",
    "document_number": "751",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 751 Filed 08/10/22 Page 194 of 261 1355 LC6VMAX6\n\n1 MS. MODE: Yes, your Honor. And I'd be happy to speak\n2 to why we've decided not to do that in this case, both for Jane\n3 and Kate, since this has come up now twice. I'd be happy to\n4 explain why we've approached this this way. Because we tried\n5 to be sensitive in the way we've approached our interviews with\n6 victims in this case. We've done this for two reasons. One,\n7 the defense has put in issue the quality of the victims'\n8 memories; and so it is important in terms of corroboration that\n9 we have not shown the victims --\n10 THE COURT: I get that. That is absolutely a\n11 strategic decision and an understandable one. It does not then\n12 excuse a lack of foundation as to relevancy. It just doesn't.\n13 I certainly understand why you'd make that choice, and I can\n14 imagine other reasons you'd make the choice.\n15 I don't think -- tell me if I'm wrong -- that in any\n16 way helps determine from the Court's perspective whether these\n17 2019 pictures of highly movable objects, which may or may not\n18 match up with the specific testimony of the witness, are\n19 relevant to a conspiracy that ended 15 years earlier.\n20 MS. MODE: Yes, your Honor.\n21 And I think our argument on that is that this is an\n22 issue of weight and not relevance. Because the argument before\n23 the jury from this evidence is not that these are the\n24 schoolgirl outfits or one of the schoolgirl outfits that Kate\n25 was asked to wear. The point is that Kate told the jury that\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n\nDOJ-OGR-00012945",
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      "content": "1 MS. MODE: Yes, your Honor. And I'd be happy to speak\n2 to why we've decided not to do that in this case, both for Jane\n3 and Kate, since this has come up now twice. I'd be happy to\n4 explain why we've approached this this way. Because we tried\n5 to be sensitive in the way we've approached our interviews with\n6 victims in this case. We've done this for two reasons. One,\n7 the defense has put in issue the quality of the victims'\n8 memories; and so it is important in terms of corroboration that\n9 we have not shown the victims --\n10 THE COURT: I get that. That is absolutely a\n11 strategic decision and an understandable one. It does not then\n12 excuse a lack of foundation as to relevancy. It just doesn't.\n13 I certainly understand why you'd make that choice, and I can\n14 imagine other reasons you'd make the choice.\n15 I don't think -- tell me if I'm wrong -- that in any\n16 way helps determine from the Court's perspective whether these\n17 2019 pictures of highly movable objects, which may or may not\n18 match up with the specific testimony of the witness, are\n19 relevant to a conspiracy that ended 15 years earlier.\n20 MS. MODE: Yes, your Honor.\n21 And I think our argument on that is that this is an\n22 issue of weight and not relevance. Because the argument before\n23 the jury from this evidence is not that these are the\n24 schoolgirl outfits or one of the schoolgirl outfits that Kate\n25 was asked to wear. The point is that Kate told the jury that",
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  "entities": {
    "people": [
      "Jane",
      "Kate",
      "MS. MODE"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22",
      "2019"
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      "1:20-cr-00330-PAE",
      "751",
      "DOJ-OGR-00012945"
    ]
  },
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}