{
  "document_metadata": {
    "page_number": "192 of 239",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 192 of 239\n\nthe Court informing the jury that, to convict on any conspiracy count, it must find at least one overt act in furtherance of the conspiracy that occurred within the statute of limitations. See Benussi, 216 F. Supp. 2d at 309 (describing a similar jury instruction provided for a conspiracy containing some allegations that were time-barred and others that were timely).\n\nSecond, the allegations regarding Minor Victim-3 in the Indictment are no more inflammatory or prejudicial than those describing the experiences of Minor Victim-1 and Minor Victim-2. The references to \"sexual abuse\" accurately describe Minor Victim-3's experience of sex acts with Epstein as traumatic, exploitative, and abusive, and she will testify to that effect at trial. Moreover, because these acts were committed in furtherance of the criminal conspiracies charged in the Indictment, it is neither misleading nor prejudicial to imply that this activity involved illegal conduct. More to the point, because evidence regarding Minor Victim-3 \"is admissible and relevant to the charge[s]\" contained in Counts One and Three of the Indictment, the language describing Minor Victim-3's experiences in the Indictment \"may not be stricken\" \"regardless of how prejudicial the language is . . . .\" Scarpa, 913 F.2d at 1013 (quoting DePalma, 461 F. Supp. at 797).\n\nFinally, even if Minor Victim-3's experiences did not constitute direct evidence of the crimes charged—which they do—this same evidence will also be admissible pursuant to Rule 404(b) to prove the defendant's knowledge, intent, and modus operandi. Federal Rule of Evidence 404(b) provides, in pertinent part:\n\nEvidence of any other crime, wrong, or act is not admissible to prove a person's character in order to show that on a particular occasion the person acted in accordance with the character. This evidence may be admissible for another purpose, such as proving motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident.\n\n165\nDOJ-OGR-00003126",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 192 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "the Court informing the jury that, to convict on any conspiracy count, it must find at least one overt act in furtherance of the conspiracy that occurred within the statute of limitations. See Benussi, 216 F. Supp. 2d at 309 (describing a similar jury instruction provided for a conspiracy containing some allegations that were time-barred and others that were timely).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Second, the allegations regarding Minor Victim-3 in the Indictment are no more inflammatory or prejudicial than those describing the experiences of Minor Victim-1 and Minor Victim-2. The references to \"sexual abuse\" accurately describe Minor Victim-3's experience of sex acts with Epstein as traumatic, exploitative, and abusive, and she will testify to that effect at trial. Moreover, because these acts were committed in furtherance of the criminal conspiracies charged in the Indictment, it is neither misleading nor prejudicial to imply that this activity involved illegal conduct. More to the point, because evidence regarding Minor Victim-3 \"is admissible and relevant to the charge[s]\" contained in Counts One and Three of the Indictment, the language describing Minor Victim-3's experiences in the Indictment \"may not be stricken\" \"regardless of how prejudicial the language is . . . .\" Scarpa, 913 F.2d at 1013 (quoting DePalma, 461 F. Supp. at 797).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, even if Minor Victim-3's experiences did not constitute direct evidence of the crimes charged—which they do—this same evidence will also be admissible pursuant to Rule 404(b) to prove the defendant's knowledge, intent, and modus operandi. Federal Rule of Evidence 404(b) provides, in pertinent part:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Evidence of any other crime, wrong, or act is not admissible to prove a person's character in order to show that on a particular occasion the person acted in accordance with the character. This evidence may be admissible for another purpose, such as proving motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident.",
      "position": "middle"
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    {
      "type": "printed",
      "content": "165",
      "position": "bottom"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00003126",
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  ],
  "entities": {
    "people": [
      "Minor Victim-1",
      "Minor Victim-2",
      "Minor Victim-3",
      "Epstein"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00003126"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving Jeffrey Epstein. The text discusses the admissibility of evidence regarding Minor Victim-3's experiences and the relevance of Rule 404(b) of the Federal Rules of Evidence. The document is well-formatted and free of significant damage or redactions."
}