mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00014356.json

{
  "document_metadata": {
    "page_number": "52",
    "document_number": "765",
    "date": "08/10/22",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 52 of 95 2790 LCI1MAX1 brackets or something. So are you okay with \"alleges\" there, Mr. Everdell? MR. EVERDELL: Well, let me see about that. Are we talking just about the overt acts with respect to Jane or are we talking about with Annie as well? Because the overt act with respect to Annie is, she's saying she's under the age of 18, but the age of consent there is 16, so -- and Kate -- there are a few issues here, so I'll just lay them out. The instruction with Annie is, you know, there's the age of consent issue with Annie. But skipping to Kate, which is No. 4, on line 18, I don't think that should be in there at all because that invites them to base an overt act and convict the defendant based on Kate's testimony, which the Court has already instructed that the jury can't. So, I mean, if they found that this element was satisfied solely with Kate's testimony, that would be an improper conviction. So that shouldn't be included. MR. ROHRBACH: Insofar as we're no longer following the exact text of the indictment, the government would be fine with deleting the overt act relevant to Kate for the reason Mr. Everdell stated. THE COURT: Okay. All right. MR. EVERDELL: All right. So then I think we could probably say with respect to 1 and 2, which we're talking about SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014356",
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      "content": "Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 52 of 95 2790 LCI1MAX1",
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      "type": "printed",
      "content": "brackets or something. So are you okay with \"alleges\" there, Mr. Everdell? MR. EVERDELL: Well, let me see about that. Are we talking just about the overt acts with respect to Jane or are we talking about with Annie as well? Because the overt act with respect to Annie is, she's saying she's under the age of 18, but the age of consent there is 16, so -- and Kate -- there are a few issues here, so I'll just lay them out. The instruction with Annie is, you know, there's the age of consent issue with Annie. But skipping to Kate, which is No. 4, on line 18, I don't think that should be in there at all because that invites them to base an overt act and convict the defendant based on Kate's testimony, which the Court has already instructed that the jury can't. So, I mean, if they found that this element was satisfied solely with Kate's testimony, that would be an improper conviction. So that shouldn't be included. MR. ROHRBACH: Insofar as we're no longer following the exact text of the indictment, the government would be fine with deleting the overt act relevant to Kate for the reason Mr. Everdell stated. THE COURT: Okay. All right. MR. EVERDELL: All right. So then I think we could probably say with respect to 1 and 2, which we're talking about",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "type": "printed",
      "content": "DOJ-OGR-00014356",
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  "entities": {
    "people": [
      "Mr. Everdell",
      "Jane",
      "Annie",
      "Kate",
      "Mr. Rohrbach"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "765",
      "DOJ-OGR-00014356"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a discussion between lawyers and the court about the wording of an indictment and jury instructions. The text is mostly clear, but there are some minor formatting issues."
}