{
  "document_metadata": {
    "page_number": "7",
    "document_number": "444",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 444 Filed 11/12/21 Page 7 of 21\nwith the requested massages, and during those massages, Epstein sexually abused [Accuser-3]. MAXWELL was aware that Epstein engaged in sexual activity with [Accuser-3] on multiple occasions, including at times when [Accuser-3] was under the age of 18, including in the context of a sexualized massage.\nSee Indictment (Dkt. 001) ¶ 7(c); S1 Superseding Indictment (Dkt. 017) ¶ 7(c). Both indictments also alleged the following as an overt act of the charged conspiracies: \"Between in or about 1994 and in or about 1995, when [Accuser-3] was under the age of 18, MAXWELL encouraged [Accuser-3] to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse [Accuser-3] during those massages.\" See Indictment (Dkt. 001) ¶¶ 11(d), 17(d); S1 Superseding Indictment (Dkt. 017) ¶¶ 11(d), 17(d).\nMs. Maxwell filed a pretrial motion to strike the allegations related to Accuser-3 as surplusage on the grounds that they could not support the charged conspiracies and were unfairly prejudicial to Ms. Maxwell. See Def.'s Mem. in Supp. of Mot. to Strike Surplusage from Superseding Indictment (Dkt. 146) at 1-3, 6-9. Ms. Maxwell noted that (1) according to Accuser-3's own allegations, she was above the legal age of consent in the United Kingdom (16 years old) when the sex acts supposedly took place and therefore any sex acts that occurred were lawful and could not be considered \"sexual abuse\"; and (2) the indictment did not allege any travel by Accuser-3, in interstate or foreign commerce or otherwise, let alone as a result of any action taken by Ms. Maxwell or Epstein, which was a critical element of both charged conspiracies. Id. at 4-5.\nIn its opposition, the government scrambled to paper over these problems by providing a much fuller proffer of Accuser-3's expected testimony. See Gov't Mem. in Opp. to Def.'s Pretrial Motions (Dkt. 204) at 158-59 & n.56. The government attempted to defend its use of the phrase \"sexual abuse\" by asserting that the description was \"factually accurate\" because\n3\nDOJ-OGR-00006633",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 444 Filed 11/12/21 Page 7 of 21",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "with the requested massages, and during those massages, Epstein sexually abused [Accuser-3]. MAXWELL was aware that Epstein engaged in sexual activity with [Accuser-3] on multiple occasions, including at times when [Accuser-3] was under the age of 18, including in the context of a sexualized massage.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "See Indictment (Dkt. 001) ¶ 7(c); S1 Superseding Indictment (Dkt. 017) ¶ 7(c). Both indictments also alleged the following as an overt act of the charged conspiracies: \"Between in or about 1994 and in or about 1995, when [Accuser-3] was under the age of 18, MAXWELL encouraged [Accuser-3] to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse [Accuser-3] during those massages.\" See Indictment (Dkt. 001) ¶¶ 11(d), 17(d); S1 Superseding Indictment (Dkt. 017) ¶¶ 11(d), 17(d).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell filed a pretrial motion to strike the allegations related to Accuser-3 as surplusage on the grounds that they could not support the charged conspiracies and were unfairly prejudicial to Ms. Maxwell. See Def.'s Mem. in Supp. of Mot. to Strike Surplusage from Superseding Indictment (Dkt. 146) at 1-3, 6-9. Ms. Maxwell noted that (1) according to Accuser-3's own allegations, she was above the legal age of consent in the United Kingdom (16 years old) when the sex acts supposedly took place and therefore any sex acts that occurred were lawful and could not be considered \"sexual abuse\"; and (2) the indictment did not allege any travel by Accuser-3, in interstate or foreign commerce or otherwise, let alone as a result of any action taken by Ms. Maxwell or Epstein, which was a critical element of both charged conspiracies. Id. at 4-5.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In its opposition, the government scrambled to paper over these problems by providing a much fuller proffer of Accuser-3's expected testimony. See Gov't Mem. in Opp. to Def.'s Pretrial Motions (Dkt. 204) at 158-59 & n.56. The government attempted to defend its use of the phrase \"sexual abuse\" by asserting that the description was \"factually accurate\" because",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006633",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "MAXWELL",
      "Ms. Maxwell",
      "Accuser-3"
    ],
    "organizations": [
      "DOJ"
    ],
    "locations": [
      "United Kingdom",
      "London",
      "England"
    ],
    "dates": [
      "11/12/21",
      "1994",
      "1995"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 444",
      "Dkt. 001",
      "Dkt. 017",
      "Dkt. 146",
      "Dkt. 204",
      "DOJ-OGR-00006633"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ghislaine Maxwell. The text discusses allegations against Maxwell and Epstein, and the government's response to Maxwell's pretrial motions. The document is a printed text with no handwritten content or stamps."
}