mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00014064.json

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    "page_number": "205",
    "document_number": "761",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 761 Filed 08/10/22 Page 205 of 246 2500 LCGCmax6 Aznaran - direct 1 (Jury not present) 2 THE COURT: Okay. Mr. Everdell. 3 MR. EVERDELL: Your Honor, the exhibit is marked for identification as MA1, and I'll hand up a paper copy to the Court, and I believe the government has a copy, but I have another one for them, as well. 4 5 THE COURT: Okay. I'll hear the objection. 6 MS. POMERANTZ: Thank you, your Honor. Just briefly, the question posed to the defense is what is the relevance of these records, and in particular, we're talking about victim travel records that go over 15 years of victim travel records that extend well beyond the period charged in the indictment. And so, we would ask for a proffer of relevance for the admissibility of such extensive travel information, private information of the victims. 7 8 THE COURT: So no objection within the charged timeframe? 9 MS. POMERANTZ: No objection. 10 MR. EVERDELL: Your Honor, for example, these records go up to 2010, which was the cutoff point for the request when we issued the subpoena, we, in fact, negotiated with the government over how broad the subpoena would be and we agreed that it would go to 2010. 11 12 Now, as to the relevance -- and that's why the records go that far. 13 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014064",
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      "content": "(Jury not present) THE COURT: Okay. Mr. Everdell. MR. EVERDELL: Your Honor, the exhibit is marked for identification as MA1, and I'll hand up a paper copy to the Court, and I believe the government has a copy, but I have another one for them, as well. THE COURT: Okay. I'll hear the objection. MS. POMERANTZ: Thank you, your Honor. Just briefly, the question posed to the defense is what is the relevance of these records, and in particular, we're talking about victim travel records that go over 15 years of victim travel records that extend well beyond the period charged in the indictment. And so, we would ask for a proffer of relevance for the admissibility of such extensive travel information, private information of the victims. THE COURT: So no objection within the charged timeframe? MS. POMERANTZ: No objection. MR. EVERDELL: Your Honor, for example, these records go up to 2010, which was the cutoff point for the request when we issued the subpoena, we, in fact, negotiated with the government over how broad the subpoena would be and we agreed that it would go to 2010. Now, as to the relevance -- and that's why the records go that far.",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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  "entities": {
    "people": [
      "Mr. Everdell",
      "Ms. Pomerantz"
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    "dates": [
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