mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00014203.json

{
  "document_metadata": {
    "page_number": "97",
    "document_number": "763",
    "date": "08/10/22",
    "document_type": "court transcript",
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  "full_text": "Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 97 of 197 2638\nLCHCmax3 Dubin - direct\n1 (At the sidebar)\n2 MS. MOE: Thank you. Your Honor, this is an issue I believe we raised in advance of trial about the relevance of asking witnesses about uncharged conduct and whether the defendant or Epstein committed crimes in other instances that are not charged. I think the foundation here is about the entirety of a very broad relationship between, I think, the 1980s and the present, and the question is whether, over several decades, she was aware of any kind of inappropriate conduct with other people. It's extraordinarily broad. And as we briefed in advance of trial, there is no relevance, it's inappropriate to suggest that there are uncharged conduct on other occasions is probative of what happened with the particular individuals at issue in this case. So we think this line of questioning is inappropriate.\n16 I would also note, your Honor, as we briefed in advance of this witness's testimony, we don't believe there is a foundation to suggest that this person was in the room with Jane. We think our notes on this are clear, that Jane has expressly said that this person was not involved in sexualized massages. So we think that questions that are designed to impeach and the misimpression that defense counsel has created are inappropriate.\n24 And for those reasons, we would object.\n25 THE COURT: So the specific objection is to other than\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014203",
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      "content": "Case 1:20-cr-00330-PAE Document 763 Filed 08/10/22 Page 97 of 197 2638",
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    {
      "type": "printed",
      "content": "LCHCmax3 Dubin - direct",
      "position": "header"
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    {
      "type": "printed",
      "content": "(At the sidebar)\nMS. MOE: Thank you. Your Honor, this is an issue I believe we raised in advance of trial about the relevance of asking witnesses about uncharged conduct and whether the defendant or Epstein committed crimes in other instances that are not charged. I think the foundation here is about the entirety of a very broad relationship between, I think, the 1980s and the present, and the question is whether, over several decades, she was aware of any kind of inappropriate conduct with other people. It's extraordinarily broad. And as we briefed in advance of trial, there is no relevance, it's inappropriate to suggest that there are uncharged conduct on other occasions is probative of what happened with the particular individuals at issue in this case. So we think this line of questioning is inappropriate.\nI would also note, your Honor, as we briefed in advance of this witness's testimony, we don't believe there is a foundation to suggest that this person was in the room with Jane. We think our notes on this are clear, that Jane has expressly said that this person was not involved in sexualized massages. So we think that questions that are designed to impeach and the misimpression that defense counsel has created are inappropriate.\nAnd for those reasons, we would object.\nTHE COURT: So the specific objection is to other than",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00014203",
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  "entities": {
    "people": [
      "MS. MOE",
      "Epstein",
      "Jane"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22",
      "1980s"
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      "1:20-cr-00330-PAE",
      "763",
      "DOJ-OGR-00014203"
    ]
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}