{
  "document_metadata": {
    "page_number": "206",
    "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 206 of 239\nminor girls to travel with the intent that they engage in sexual activity with Epstein, aiding and abetting the transportation and enticement of a particular minor girl interstate for the purpose of engaging in sex acts with Epstein, and lying about those same crimes during her 2016 civil deposition testimony. The charged time periods are made plain in each count, as is the statute she is accused of violating.\nThe speaking Indictment in this case goes above and beyond a mere recitation of the elements of each offense by detailing the defendant's specific role in the crimes charged. Among other things, it specifies three minor victims in particular and describes the steps the defendant took with respect to each as part of the charged crimes. See, e.g., Indictment ¶ 7. Additionally, the Indictment details the types of sex acts that Epstein committed with the minor victims as part of the charged crimes and the locations where those acts occurred. See, e.g., id. ¶¶ 5-6. In this way, the Indictment makes clear the Government's theory that the defendant groomed three minor girls to engage in sex acts in Florida, New Mexico, New York, and London with Epstein between 1994 and 1997. The Indictment further specifies during which portion of that period each of those three victims interacted with the defendant and Epstein as minors. See id. ¶ 7. Additionally, the Indictment identifies the precise answers that the Government alleges constituted perjury, and alleges facts, in the earlier portions of the Indictment, that indicate how and why the Government will seek to prove the answers were false. Compare id. ¶¶ 21, 23 with id. ¶¶ 1-11. Simply put, this is not a case in which the allegations in the Indictment \"are so general that they do not advise the defendant of the specific acts of which he is accused.\" Walsh, 194 F.3d at 47 (internal quotation mark omitted) (quoting Torres, 901 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) (\"'[E]videntiary detail is not the function of the bill of particulars.'\n179\nDOJ-OGR-00003140",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 206 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "minor girls to travel with the intent that they engage in sexual activity with Epstein, aiding and abetting the transportation and enticement of a particular minor girl interstate for the purpose of engaging in sex acts with Epstein, and lying about those same crimes during her 2016 civil deposition testimony. The charged time periods are made plain in each count, as is the statute she is accused of violating.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The speaking Indictment in this case goes above and beyond a mere recitation of the elements of each offense by detailing the defendant's specific role in the crimes charged. Among other things, it specifies three minor victims in particular and describes the steps the defendant took with respect to each as part of the charged crimes. See, e.g., Indictment ¶ 7. Additionally, the Indictment details the types of sex acts that Epstein committed with the minor victims as part of the charged crimes and the locations where those acts occurred. See, e.g., id. ¶¶ 5-6. In this way, the Indictment makes clear the Government's theory that the defendant groomed three minor girls to engage in sex acts in Florida, New Mexico, New York, and London with Epstein between 1994 and 1997. The Indictment further specifies during which portion of that period each of those three victims interacted with the defendant and Epstein as minors. See id. ¶ 7. Additionally, the Indictment identifies the precise answers that the Government alleges constituted perjury, and alleges facts, in the earlier portions of the Indictment, that indicate how and why the Government will seek to prove the answers were false. Compare id. ¶¶ 21, 23 with id. ¶¶ 1-11. Simply put, this is not a case in which the allegations in the Indictment \"are so general that they do not advise the defendant of the specific acts of which he is accused.\" Walsh, 194 F.3d at 47 (internal quotation mark omitted) (quoting Torres, 901 F.2d at 234). Thus, the Indictment itself provides a sufficient basis to deny the defendant's motion in its entirety. See, e.g., United States v. Bonventre, 646 F App'x 73, 79 (2d Cir. 2016) (\"'[E]videntiary detail is not the function of the bill of particulars.'",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "179",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003140",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [
      "Florida",
      "New Mexico",
      "New York",
      "London"
    ],
    "dates": [
      "04/16/21",
      "1994",
      "1997",
      "2016"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00003140"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Jeffrey Epstein. The text is printed and there are no visible stamps or handwritten notes. The document is from a legal case and includes legal citations and references to specific sections of an indictment."
}