mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00013019.json

{
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    "page_number": "6",
    "document_number": "753",
    "date": "08/10/22",
    "document_type": "court transcript",
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  "full_text": "Case 1:20-cr-00330-PAE Document 753 Filed 08/10/22 Page 6 of 264 1428 LC7VMAX1\n\n1    that she was potentially subject to recall and recross. And so\n2    my understanding is that he understood the rules about that;\n3    and that we couldn't speak with her; and that she was still a\n4    trial witness subject to recall. I don't remember whether I\n5    repeated, sort of, the ground rules about trial witnesses.\n6    That's all I remember from that conversation, your Honor.\n\n7    THE COURT: And did the government prior to trial\n8    give -- was there any direction given on this issue -- since\n9    this witness is being provided for prior consistent statements,\n10   did the government give any direction either to the witnesses\n11   or to their counsel that they ought not to confer in light of\n12   the reason that the witness is being offered?\n13\n14   MS. MOE: Yes, your Honor.\n15   Off the top of my head, I can't point to a particular\n16   date or a particular conversation; but it's our practice -- and\n17   what we did in this case -- is to tell every witness that their\n18   memory should be their memories and they shouldn't be talking\n19   to other witnesses before the trial. So I'm confident we did\n20   that in this case; I just can't remember a particular date of a\n21   particular conversation, but we've been having those\n22   conversations with all of our witnesses.\n23   THE COURT: And how did the government learn about\n24   this conversation?\n25   MS. MOE: Last night we had a meeting with Brian. And\n     he, unprompted, mentioned that he had heard from Jane that she\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "type": "printed",
      "content": "that she was potentially subject to recall and recross. And so\nmy understanding is that he understood the rules about that;\nand that we couldn't speak with her; and that she was still a\ntrial witness subject to recall. I don't remember whether I\nrepeated, sort of, the ground rules about trial witnesses.\nThat's all I remember from that conversation, your Honor.\n\nTHE COURT: And did the government prior to trial\ngive -- was there any direction given on this issue -- since\nthis witness is being provided for prior consistent statements,\ndid the government give any direction either to the witnesses\nor to their counsel that they ought not to confer in light of\nthe reason that the witness is being offered?\n\nMS. MOE: Yes, your Honor.\n\nOff the top of my head, I can't point to a particular\ndate or a particular conversation; but it's our practice -- and\nwhat we did in this case -- is to tell every witness that their\nmemory should be their memories and they shouldn't be talking\nto other witnesses before the trial. So I'm confident we did\nthat in this case; I just can't remember a particular date of a\nparticular conversation, but we've been having those\nconversations with all of our witnesses.\n\nTHE COURT: And how did the government learn about\nthis conversation?\n\nMS. MOE: Last night we had a meeting with Brian. And\nhe, unprompted, mentioned that he had heard from Jane that she",
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Brian",
      "Jane",
      "MS. MOE"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "753",
      "DOJ-OGR-00013019"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}