mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00014381.json

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    "page_number": "77",
    "document_number": "765",
    "date": "08/10/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 77 of 95 2815 LCIAMAX2ps\n\n1 So there is more than just the one witness who indicated that she was going to invoke had the defense called her. There were other co-conspirators who the government chose not to call, not to immunize, and we couldn't possibly call in our defense without -- because we can't give any immunity ourselves.\n2\n3 MR. ROHRBACH: Your Honor, this is true in basically every conspiracy case and every gang case that is prosecuted in this district. There are unindicted co-conspirators. Yet this instruction is given and is the run-of-the-mill instruction, as the Court said, in cases in this district.\n4\n5 MR. EVERDELL: Your Honor, if the Court is inclined to give the instruction, I can propose an alternative.\n6\n7 THE COURT: I will take an alternative.\n8\n9 MR. EVERDELL: If we can just eliminate the language in the title of the charge that says \"equally available to both sides\" and just have \"the uncalled witnesses.\"\n10\n11 I believe there's also language that says \"equal opportunity.\"\n12\n13 THE COURT: Or lack of opportunity.\n14\n15 MR. EVERDELL: Yes.\n16\n17 MR. ROHRBACH: This is the uncalled witness instruction, your Honor. This is the instruction given, suggested by Sand and given by this Court. I have five examples right here where the Court has given this instruction.\n18\n19 THE COURT: As I say, it's always given, always\n20\n21 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n22\n23 DOJ-OGR-00014381",
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      "content": "1 So there is more than just the one witness who indicated that she was going to invoke had the defense called her. There were other co-conspirators who the government chose not to call, not to immunize, and we couldn't possibly call in our defense without -- because we can't give any immunity ourselves.\n2\n3 MR. ROHRBACH: Your Honor, this is true in basically every conspiracy case and every gang case that is prosecuted in this district. There are unindicted co-conspirators. Yet this instruction is given and is the run-of-the-mill instruction, as the Court said, in cases in this district.\n4\n5 MR. EVERDELL: Your Honor, if the Court is inclined to give the instruction, I can propose an alternative.\n6\n7 THE COURT: I will take an alternative.\n8\n9 MR. EVERDELL: If we can just eliminate the language in the title of the charge that says \"equally available to both sides\" and just have \"the uncalled witnesses.\"\n10\n11 I believe there's also language that says \"equal opportunity.\"\n12\n13 THE COURT: Or lack of opportunity.\n14\n15 MR. EVERDELL: Yes.\n16\n17 MR. ROHRBACH: This is the uncalled witness instruction, your Honor. This is the instruction given, suggested by Sand and given by this Court. I have five examples right here where the Court has given this instruction.\n18\n19 THE COURT: As I say, it's always given, always\n20",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00014381",
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  "entities": {
    "people": [
      "MR. ROHRBACH",
      "MR. EVERDELL"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "DOJ"
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    "locations": [],
    "dates": [
      "08/10/22"
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      "1:20-cr-00330-PAE",
      "765",
      "DOJ-OGR-00014381"
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