mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00013210.json

{
  "document_metadata": {
    "page_number": "197",
    "document_number": "753",
    "date": "08/10/22",
    "document_type": "court transcript",
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    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 753 Filed 08/10/22 Page 197 of 264 1638 LC7Cmax6 Carolyn - cross 1 factual inconsistency. 2 MR. PAGLIUCA: Well, your Honor, there are two principals at play here. 3 The first is this is what is commonly referred to as impeachment by omission, which is a subset of impeachment by contradiction. Impeachment by omission typically occurs where there is a document or a statement where the witness would likely include whatever is omitted, and this is such a document, and I am seeking to impeach by omission through this document. This is a complaint against two people that this witness claims sexually abused her. It's not only against Epstein, it's against one of Epstein's employees who is highlighted in this complaint. The entire testimony by the government here through this witness has downplayed the role of Sarah Kellen and up-played the role of Ghislaine Maxwell, and it is an impeachment by omission that, in 2008, shortly after being interviewed by the FBI about the same subject matter with counsel, there is no mention of Maxwell in this entire complaint. I think that is significant under the facts of this case. So, I think it is admissible under that theory and there is ample federal law, First Circuit, this circuit, that supports that theory of impeachment by omission. And these factual paragraphs, I believe, are also impeaching of the witness's testimony because it is inconsistent with the things that she has claimed happened to her in addition to these SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00013210",
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      "content": "1 factual inconsistency. 2 MR. PAGLIUCA: Well, your Honor, there are two principals at play here. 3 The first is this is what is commonly referred to as impeachment by omission, which is a subset of impeachment by contradiction. Impeachment by omission typically occurs where there is a document or a statement where the witness would likely include whatever is omitted, and this is such a document, and I am seeking to impeach by omission through this document. This is a complaint against two people that this witness claims sexually abused her. It's not only against Epstein, it's against one of Epstein's employees who is highlighted in this complaint. The entire testimony by the government here through this witness has downplayed the role of Sarah Kellen and up-played the role of Ghislaine Maxwell, and it is an impeachment by omission that, in 2008, shortly after being interviewed by the FBI about the same subject matter with counsel, there is no mention of Maxwell in this entire complaint. I think that is significant under the facts of this case. So, I think it is admissible under that theory and there is ample federal law, First Circuit, this circuit, that supports that theory of impeachment by omission. And these factual paragraphs, I believe, are also impeaching of the witness's testimony because it is inconsistent with the things that she has claimed happened to her in addition to these",
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00013210",
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  ],
  "entities": {
    "people": [
      "MR. PAGLIUCA",
      "Epstein",
      "Sarah Kellen",
      "Ghislaine Maxwell",
      "Maxwell"
    ],
    "organizations": [
      "FBI",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22",
      "2008"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "753",
      "DOJ-OGR-00013210"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}