mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00013838.json

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  "document_metadata": {
    "page_number": "247",
    "document_number": "759",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 759 Filed 08/10/22 Page 247 of 267 2275 LCAVMAX8\n\n1 THE COURT: Okay.\n2 MR. PAGLIUCA: But the problem is, you know, we have a\n3 larger list that we've needed to winnow down, given the fact\n4 that the government has rested early and has not called a\n5 significant number of witnesses.\n6 We also have the problem of travel for this period of\n7 time with some of our witnesses. And we're confirming who's\n8 available. And we have been confirming who's available and\n9 who's not available and when. And there may be the need to\n10 substitute a different witness on the same topic.\n11 But what I expect to be able to do tonight is to send\n12 the government what we believe our good-faith list is. And\n13 there will be some, I expect, adjustment to that as we move\n14 along. But that's our anticipated goal here, your Honor.\n15 MS. MOE: Your Honor, the government warned the\n16 defense multiple times this week that we would rest. The Court\n17 ordered the defense to produce these materials at the\n18 conclusion of the government's case, long before the trial.\n19 And we submit the defense should do just that.\n20 With respect to Rule 26 materials, especially given\n21 that there are experts in this case, there should be Rule 26\n22 materials, including communications with experts, things like\n23 contracts and payment materials. And if there were going to be\n24 defense witnesses, any notes of interviews with those witnesses\n25 are governed by Rule 26 and are subject to disclosure today.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00013838",
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      "content": "1 THE COURT: Okay.\n2 MR. PAGLIUCA: But the problem is, you know, we have a\n3 larger list that we've needed to winnow down, given the fact\n4 that the government has rested early and has not called a\n5 significant number of witnesses.\n6 We also have the problem of travel for this period of\n7 time with some of our witnesses. And we're confirming who's\n8 available. And we have been confirming who's available and\n9 who's not available and when. And there may be the need to\n10 substitute a different witness on the same topic.\n11 But what I expect to be able to do tonight is to send\n12 the government what we believe our good-faith list is. And\n13 there will be some, I expect, adjustment to that as we move\n14 along. But that's our anticipated goal here, your Honor.\n15 MS. MOE: Your Honor, the government warned the\n16 defense multiple times this week that we would rest. The Court\n17 ordered the defense to produce these materials at the\n18 conclusion of the government's case, long before the trial.\n19 And we submit the defense should do just that.\n20 With respect to Rule 26 materials, especially given\n21 that there are experts in this case, there should be Rule 26\n22 materials, including communications with experts, things like\n23 contracts and payment materials. And if there were going to be\n24 defense witnesses, any notes of interviews with those witnesses\n25 are governed by Rule 26 and are subject to disclosure today.",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "DOJ-OGR-00013838",
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  "entities": {
    "people": [
      "MR. PAGLIUCA",
      "MS. MOE"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "08/10/22"
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      "1:20-cr-00330-PAE",
      "759",
      "DOJ-OGR-00013838"
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}