{
  "document_metadata": {
    "page_number": "155",
    "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 155 of 239 interactions with the defendant and Epstein at Epstein's various properties. See, e.g., Indictment ¶ 7(a) (“MAXWELL subsequently interacted with Minor Victim-1 on multiple occasions at Epstein's residences.”). Accordingly, a rational juror, after hearing the evidence, could find that the question called for the names of minors that the defendant interacted with at any of Jeffrey Epstein's properties, that the defendant answered that she was aware of no such minors other than Giuffre, and therefore that her answer was false. And even if the defendant identifies some plausible ambiguity—and she has not—the terms in this question are ones “with a meaning about which [people] of ordinary intellect could agree,” and therefore are not fundamentally ambiguous. Lighte, 782 F.2d at 375 (internal quotation marks omitted). The defendant points out that, in response to an earlier question asking her to list the underage girls she “met and brought” to Epstein's house, she said that she could not do so. (Def. Mot. 4 at 12-13). She argues that the charged question was “improper” because it asked her to generate a list “from events that had happened nearly two decades previously.” (Id.). Her unpersuasive after-the-fact efforts to justify her answer provide no basis to keep this question from the jury. As noted above, the transcript makes clear (and a jury could find) that when the defendant did not understand or could not answer a question, she said so. To the extent the defendant is arguing that her answer was literally true, a reasonable jury could find otherwise. In this respect, the Government notes, among other things, that in response to the earlier question, the defendant said that she could not make a list not because she could not remember events from that long ago but “because that list -- it never happened that I can think of.” (Ex. 10 at 382:4-13) (emphasis added). And in response to the charged question, the defendant said that she “was not aware of anybody” under 18—that is, the list would be empty. See Forde, 740 F. Supp. 2d at 413 (“Olivieri, if truly confused, could also have asked for clarification. Instead he replied with a strong 128 DOJ-OGR-00003089",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 155 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "interactions with the defendant and Epstein at Epstein's various properties. See, e.g., Indictment ¶ 7(a) (“MAXWELL subsequently interacted with Minor Victim-1 on multiple occasions at Epstein's residences.”). Accordingly, a rational juror, after hearing the evidence, could find that the question called for the names of minors that the defendant interacted with at any of Jeffrey Epstein's properties, that the defendant answered that she was aware of no such minors other than Giuffre, and therefore that her answer was false. And even if the defendant identifies some plausible ambiguity—and she has not—the terms in this question are ones “with a meaning about which [people] of ordinary intellect could agree,” and therefore are not fundamentally ambiguous. Lighte, 782 F.2d at 375 (internal quotation marks omitted). The defendant points out that, in response to an earlier question asking her to list the underage girls she “met and brought” to Epstein's house, she said that she could not do so. (Def. Mot. 4 at 12-13). She argues that the charged question was “improper” because it asked her to generate a list “from events that had happened nearly two decades previously.” (Id.). Her unpersuasive after-the-fact efforts to justify her answer provide no basis to keep this question from the jury. As noted above, the transcript makes clear (and a jury could find) that when the defendant did not understand or could not answer a question, she said so. To the extent the defendant is arguing that her answer was literally true, a reasonable jury could find otherwise. In this respect, the Government notes, among other things, that in response to the earlier question, the defendant said that she could not make a list not because she could not remember events from that long ago but “because that list -- it never happened that I can think of.” (Ex. 10 at 382:4-13) (emphasis added). And in response to the charged question, the defendant said that she “was not aware of anybody” under 18—that is, the list would be empty. See Forde, 740 F. Supp. 2d at 413 (“Olivieri, if truly confused, could also have asked for clarification. Instead he replied with a strong",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "128",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003089",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "MAXWELL",
      "Minor Victim-1",
      "Jeffrey Epstein",
      "Giuffre",
      "Olivieri"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00003089"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ghislaine Maxwell, discussing her interactions with Jeffrey Epstein and Minor Victim-1. The text references various legal precedents and includes citations to specific exhibits and court documents."
}