{
  "document_metadata": {
    "page_number": "3",
    "document_number": "202",
    "date": "04/15/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 202 Filed 04/15/21 Page 3 of 8\nLAW OFFICES OF BOBBI C. STERNHEIM\nmaterials in the MDC. Although defense counsel have not yet been able to fully review the materials, which are voluminous, it is apparent that the witness interviews contain exculpatory or otherwise favorable information for Ms. Maxwell, which the defense has an obligation to investigate. A number of these witnesses may testify as part of the defense case. Even if defense counsel were to attempt to contact and interview only a small number of these witnesses and conduct any necessary follow-up investigation, that would still take a significant amount of time to complete. Thus, while we appreciate receiving these materials, the disclosure has not decreased the amount of time the defense will need to investigate; indeed, it has increased it.\nIt is also disingenuous for the government to argue that because it previously provided discovery regarding the new charges no additional time is required to prepare the defense of the new indictment. When the parties were originally negotiating a discovery schedule for the original indictment, the government represented that it would be providing, in an abundance of caution, a significant amount of discovery from Epstein's seized electronic devices that contained information that it was not relying on in Ms. Maxwell's case. The government reiterated this point in its November 6, 2020 letter to the Court requesting additional time to finish producing discovery. (See Dkt. 69 at 4 (\"Of the approximately 1.2 million documents, only a handful were specifically relied upon by the Government in the investigation that led the charges in the current indictment.\"). These devices contain over 2.4 million pages of material, virtually none of which pertained to the time period of the original indictment. Now that the superseding indictment has expanded the time period of the alleged conduct well into the 2000s, the 2.4 million pages that were not previously relevant are now pertinent, requiring re-review and analysis.1\n1 The actual number of pages is, in fact, larger than 2.4 million. For example, the discovery from these devices included forensic Cellebrite images of several individual devices that were assigned a single Bates number.",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 202 Filed 04/15/21 Page 3 of 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LAW OFFICES OF BOBBI C. STERNHEIM",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "materials in the MDC. Although defense counsel have not yet been able to fully review the materials, which are voluminous, it is apparent that the witness interviews contain exculpatory or otherwise favorable information for Ms. Maxwell, which the defense has an obligation to investigate. A number of these witnesses may testify as part of the defense case. Even if defense counsel were to attempt to contact and interview only a small number of these witnesses and conduct any necessary follow-up investigation, that would still take a significant amount of time to complete. Thus, while we appreciate receiving these materials, the disclosure has not decreased the amount of time the defense will need to investigate; indeed, it has increased it.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "It is also disingenuous for the government to argue that because it previously provided discovery regarding the new charges no additional time is required to prepare the defense of the new indictment. When the parties were originally negotiating a discovery schedule for the original indictment, the government represented that it would be providing, in an abundance of caution, a significant amount of discovery from Epstein's seized electronic devices that contained information that it was not relying on in Ms. Maxwell's case. The government reiterated this point in its November 6, 2020 letter to the Court requesting additional time to finish producing discovery. (See Dkt. 69 at 4 (\"Of the approximately 1.2 million documents, only a handful were specifically relied upon by the Government in the investigation that led the charges in the current indictment.\"). These devices contain over 2.4 million pages of material, virtually none of which pertained to the time period of the original indictment. Now that the superseding indictment has expanded the time period of the alleged conduct well into the 2000s, the 2.4 million pages that were not previously relevant are now pertinent, requiring re-review and analysis.1",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "1 The actual number of pages is, in fact, larger than 2.4 million. For example, the discovery from these devices included forensic Cellebrite images of several individual devices that were assigned a single Bates number.",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Epstein",
      "BOBBI C. STERNHEIM"
    ],
    "organizations": [
      "LAW OFFICES OF BOBBI C. STERNHEIM",
      "Government",
      "Court"
    ],
    "locations": [],
    "dates": [
      "04/15/21",
      "November 6, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 202",
      "Dkt. 69"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text discusses the discovery process and the challenges faced by the defense team in reviewing the voluminous materials provided by the government. The document includes a footnote that provides additional context regarding the number of pages in the discovery materials."
}