{
  "document_metadata": {
    "page_number": "42 of 52",
    "document_number": "398",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 42 of 52\n\nAs evidenced by their recently disclosed interviews, the government lawyers, despite its protests about the defense's ability to call percipient fact witnesses, have been preparing the case agents for months to testify in the defense's case. The risk highlighted by the defense it its footnote is that, even though they are not asked a question that calls for opinion testimony, the agents are likely to try to offer their opinions either during the defense's questioning or when the government attempts to rehabilitate them. Because neither side has noticed any opinion testimony from the case agents, they should be prohibited from offering any, especially because it will be non-responsive to any questions that should be asked of them.\n\nIX. THE COURT SHOULD PRECLUDE TESTIMONY ABOUT ANY ALLEGED \"RAPE\" BY JEFFREY EPSTEIN\n\nThe government argues that the expected testimony of ________ that she was raped by Jeffrey Epstein is admissible to show the \"ongoing relationships between the defendant, Epstein, and the victims\" and is necessary \"to complete the story of the crime on trial.\" Resp. at 79-80. The government offers no explanation, however, for why testimony of an alleged rape would prove the relationship \"between the defendant, Epstein, and the victims\" when ________ has never claimed in her prior statements to the FBI or anywhere else that Ms. Maxwell knew of, facilitated, or participated in the alleged rape in any way. Nor does the government explain why this testimony is somehow necessary \"to complete the story of the crime on trial\" when the rape allegation is an outlier and does not fit the \"story\" of alleged sexual abuse that the government has described in the S2 Indictment—namely, \"grooming\" the alleged victims to gradually break down their inhibitions so that forcible rape is not required to engage in sexual activity with them.\n\nBecause the rape allegation is the only one of its kind and has no connection to the other incidents of alleged sexual abuse, it should not be admitted as intrinsic proof of the charged crimes. See United States v. Townsend, No. S1 06 CR. 34 (JFK), 2007 WL 1288597, at *2\n\n36\nDOJ-OGR-00005997",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 42 of 52",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "As evidenced by their recently disclosed interviews, the government lawyers, despite its protests about the defense's ability to call percipient fact witnesses, have been preparing the case agents for months to testify in the defense's case. The risk highlighted by the defense it its footnote is that, even though they are not asked a question that calls for opinion testimony, the agents are likely to try to offer their opinions either during the defense's questioning or when the government attempts to rehabilitate them. Because neither side has noticed any opinion testimony from the case agents, they should be prohibited from offering any, especially because it will be non-responsive to any questions that should be asked of them.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "IX. THE COURT SHOULD PRECLUDE TESTIMONY ABOUT ANY ALLEGED \"RAPE\" BY JEFFREY EPSTEIN",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government argues that the expected testimony of ________ that she was raped by Jeffrey Epstein is admissible to show the \"ongoing relationships between the defendant, Epstein, and the victims\" and is necessary \"to complete the story of the crime on trial.\" Resp. at 79-80. The government offers no explanation, however, for why testimony of an alleged rape would prove the relationship \"between the defendant, Epstein, and the victims\" when ________ has never claimed in her prior statements to the FBI or anywhere else that Ms. Maxwell knew of, facilitated, or participated in the alleged rape in any way. Nor does the government explain why this testimony is somehow necessary \"to complete the story of the crime on trial\" when the rape allegation is an outlier and does not fit the \"story\" of alleged sexual abuse that the government has described in the S2 Indictment—namely, \"grooming\" the alleged victims to gradually break down their inhibitions so that forcible rape is not required to engage in sexual activity with them.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Because the rape allegation is the only one of its kind and has no connection to the other incidents of alleged sexual abuse, it should not be admitted as intrinsic proof of the charged crimes. See United States v. Townsend, No. S1 06 CR. 34 (JFK), 2007 WL 1288597, at *2",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "36",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005997",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Ms. Maxwell",
      "JFK"
    ],
    "organizations": [
      "FBI"
    ],
    "locations": [],
    "dates": [
      "10/29/21",
      "2007"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 398",
      "S1 06 CR. 34",
      "DOJ-OGR-00005997"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ghislaine Maxwell, with discussions about the admissibility of certain testimony regarding Jeffrey Epstein's alleged rape of a victim. The document is well-formatted and free of significant damage or redactions."
}