{
  "document_metadata": {
    "page_number": "34",
    "document_number": "380",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 380 Filed 10/29/21 Page 34 of 54\n\nabout numerous witness interviews they conducted, physical evidence they reviewed, documents they obtained by subpoena, and their activities before the grand jury. (Ex. A at 1-2).\n\nBut as set forth above, testimony about the “resolution” of a prior investigation is irrelevant hearsay that would only serve to confuse the jury. Evidence about the “scope,” “timeline,” or “various investigative steps taken by the agents” is similarly irrelevant and misleading. The case agents are not summary witnesses that the defense can use to place before the jury sweeping conclusions about the Florida Investigations or this one.9 The bases identified for their testimony are improper, and the Court should preclude them unless the defense identifies a specific, valid purpose for their testimony.\n\nIV. The Court Should Preclude Evidence or Argument About the Government’s Alleged Motives for Prosecution\n\nAs the Court is aware, the defendant has claimed that she is being prosecuted as a scapegoat because Jeffrey Epstein is dead. (See, e.g., Mem. of Law, Dkt. No. 142, at 1 (“[T]he government has sought to substitute our client for Jeffrey Epstein . . .”)). That claim is as false as it is offensive. But in any event, the Government’s motives for prosecution are irrelevant to the question of the defendant’s factual guilt that will be before the jury at trial, and any probative\n\n9 Furthermore, the proffered bases for the case agents’ testimony will likely run afoul of numerous evidentiary rules. The Government’s case agents cannot testify to the substance of “numerous witness interviews they conducted” with uncalled witnesses, which is hearsay. The agents’ prior testimony before the grand jury is admissible only under the limited principles that govern prior consistent or inconsistent statements. And there is significant risk that case agent testimony will introduce additional evidentiary issues. For instance, questioning the case agents about information their investigations generated about the defendant would likely yield hearsay responses and would open the door to agents offering other information that is inculpatory to the defendant and that the Government would not otherwise offer at trial.\n\n33\n\nDOJ-OGR-00005427",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 380 Filed 10/29/21 Page 34 of 54",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "about numerous witness interviews they conducted, physical evidence they reviewed, documents they obtained by subpoena, and their activities before the grand jury. (Ex. A at 1-2).\n\nBut as set forth above, testimony about the “resolution” of a prior investigation is irrelevant hearsay that would only serve to confuse the jury. Evidence about the “scope,” “timeline,” or “various investigative steps taken by the agents” is similarly irrelevant and misleading. The case agents are not summary witnesses that the defense can use to place before the jury sweeping conclusions about the Florida Investigations or this one.9 The bases identified for their testimony are improper, and the Court should preclude them unless the defense identifies a specific, valid purpose for their testimony.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "IV. The Court Should Preclude Evidence or Argument About the Government’s Alleged Motives for Prosecution",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "As the Court is aware, the defendant has claimed that she is being prosecuted as a scapegoat because Jeffrey Epstein is dead. (See, e.g., Mem. of Law, Dkt. No. 142, at 1 (“[T]he government has sought to substitute our client for Jeffrey Epstein . . .”)). That claim is as false as it is offensive. But in any event, the Government’s motives for prosecution are irrelevant to the question of the defendant’s factual guilt that will be before the jury at trial, and any probative",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "9 Furthermore, the proffered bases for the case agents’ testimony will likely run afoul of numerous evidentiary rules. The Government’s case agents cannot testify to the substance of “numerous witness interviews they conducted” with uncalled witnesses, which is hearsay. The agents’ prior testimony before the grand jury is admissible only under the limited principles that govern prior consistent or inconsistent statements. And there is significant risk that case agent testimony will introduce additional evidentiary issues. For instance, questioning the case agents about information their investigations generated about the defendant would likely yield hearsay responses and would open the door to agents offering other information that is inculpatory to the defendant and that the Government would not otherwise offer at trial.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "33",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005427",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [
      "Florida"
    ],
    "dates": [
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 380",
      "Dkt. No. 142",
      "DOJ-OGR-00005427"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with a clear structure and formatting. There are no visible handwritten annotations or stamps. The document is likely a page from a larger filing, as indicated by the page number and document number in the header."
}