{
  "document_metadata": {
    "page_number": "168",
    "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 168 of 239\noften will suffice to cure any risk of prejudice and permit joinder.\" Page, 657 F.3d at 129 (internal quotation marks omitted).\n\nB. Discussion\n\nThe perjury counts should be tried jointly with Counts One through Four. The offenses are of similar character, are logically connected and will be proved through much of the same evidence because the perjury counts concern at least some of the same conduct relevant to the crimes charged in Counts One through Four and, as such, are properly joined. See generally Potamitis, 739 F.2d at 791. Severing the counts would waste judicial resources by requiring a second trial at which the Government would offer similar proof, including by calling the same victims of sexual abuse to testify again at a second trial. The defendant has identified no prejudice sufficient to justify imposing that burden on the victims, the Court, and the Government.\n\nFirst, the Government expects to prove the offenses charged in Counts One through Four and those charged in Counts Five and Six with much of the same evidence. See United States v. Hester, No. 19 Cr. 324 (NSR), 2020 WL 3483702, at *21 (S.D.N.Y. June 26, 2020) (\"Notably, the fact that evidence of the crime charged in one count may be admissible in the Government's direct case in the trial of the other will typically defeat the need to severe the counts.\") At trial, some of the most critical evidence that the defendant committed the offenses charged in Counts One through Four will also form the crux of the Government's proof of the falsity of the defendant's deposition testimony. In particular, victim testimony and related evidence offered to prove the existence of Epstein's scheme to abuse underage girls, and Maxwell's participation therein, will also provide much of the evidence demonstrating the falsity of the statements charged in Count Five. Compare, e.g., Indictment ¶ 4(c), (e) (discussing massages resulting in sexual abuse), with id. ¶ 21 (denying interacting with underage girls and a denying a \"scheme to recruit underage girls for sexual massages\"). Similarly, aspects of that proof, such as testimony regarding the sexualized\n141\nDOJ-OGR-00003102",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 168 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "often will suffice to cure any risk of prejudice and permit joinder.\" Page, 657 F.3d at 129 (internal quotation marks omitted).\n\nB. Discussion\n\nThe perjury counts should be tried jointly with Counts One through Four. The offenses are of similar character, are logically connected and will be proved through much of the same evidence because the perjury counts concern at least some of the same conduct relevant to the crimes charged in Counts One through Four and, as such, are properly joined. See generally Potamitis, 739 F.2d at 791. Severing the counts would waste judicial resources by requiring a second trial at which the Government would offer similar proof, including by calling the same victims of sexual abuse to testify again at a second trial. The defendant has identified no prejudice sufficient to justify imposing that burden on the victims, the Court, and the Government.\n\nFirst, the Government expects to prove the offenses charged in Counts One through Four and those charged in Counts Five and Six with much of the same evidence. See United States v. Hester, No. 19 Cr. 324 (NSR), 2020 WL 3483702, at *21 (S.D.N.Y. June 26, 2020) (\"Notably, the fact that evidence of the crime charged in one count may be admissible in the Government's direct case in the trial of the other will typically defeat the need to severe the counts.\") At trial, some of the most critical evidence that the defendant committed the offenses charged in Counts One through Four will also form the crux of the Government's proof of the falsity of the defendant's deposition testimony. In particular, victim testimony and related evidence offered to prove the existence of Epstein's scheme to abuse underage girls, and Maxwell's participation therein, will also provide much of the evidence demonstrating the falsity of the statements charged in Count Five. Compare, e.g., Indictment ¶ 4(c), (e) (discussing massages resulting in sexual abuse), with id. ¶ 21 (denying interacting with underage girls and a denying a \"scheme to recruit underage girls for sexual massages\"). Similarly, aspects of that proof, such as testimony regarding the sexualized",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "141",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003102",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Maxwell"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "04/16/21",
      "June 26, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "19 Cr. 324 (NSR)",
      "2020 WL 3483702"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no visible handwriting or stamps. The content discusses the joinder of perjury counts with other charges and the potential prejudice to the defendant."
}