{
  "document_metadata": {
    "page_number": "6 of 12",
    "document_number": "385",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 385 Filed 10/29/21 Page 6 of 12\n229 at 3. This Court then ordered the Government to provide disclosure of any \"Rule 404(b) evidence and notice\" by October 11. Dkt. 297.\nOn October 11, 2021, the Government served on defense counsel a short letter entitled the \"Maxwell Rule 404(b) letter\" (the \"Rule 404(b) Letter\" or the \"Letter\"), attached as Exhibit A. In it, the Government referenced two sets of evidence: (a) [REDACTED], and (b) a witness, [REDACTED], who worked for Epstein between [REDACTED] (after the conclusion of the charged conspiracy) whom the Government said it \"may call\" at trial. The Government asserted in the Letter that the evidence collectively was, in its opinion, \"direct evidence of the crimes charged and, in the alternative, pursuant to Rule 404(b) as proof of the defendant's intent, preparation, plan, knowledge, identity, and/or absence of mistake of (sic) accident.\" Id. at 2. The Government stated it would not be moving in limine to seek the evidence's admission \"[b]ecause this evidence is admissible as direct evidence.\" Id. The Letter lacked identification of any particular purpose for these two categories of evidence and lacked any \"basis for concluding that the evidence is relevant in light of this purpose.\"\nAlso on October 11, the Government provided its anticipated trial exhibits. Even a quick review of those exhibits reflects the Government's apparent intent to offer numerous documents and other evidence that purportedly occurred after the conclusion of the charged conspiracy.\nSee, e.g., GX-4-D through GX-4-K (message pads dated beginning in 2005); GX-423 (an Amazon shipment to Jeffrey Epstein of an iPhone USB lightning cable in 2013); GX-501 & 502 (financial statements from June 2007); GX-661 & 662 (flight logs from 2005-13). None of these items of evidence were mentioned in the Maxwell Rule 404(b) Letter. The Government's theory of admissibility concerning this post-2004 evidence remains unclear.\n3\nDOJ-OGR-00005615",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 385 Filed 10/29/21 Page 6 of 12",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "229 at 3. This Court then ordered the Government to provide disclosure of any \"Rule 404(b) evidence and notice\" by October 11. Dkt. 297.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "On October 11, 2021, the Government served on defense counsel a short letter entitled the \"Maxwell Rule 404(b) letter\" (the \"Rule 404(b) Letter\" or the \"Letter\"), attached as Exhibit A. In it, the Government referenced two sets of evidence: (a) [REDACTED], and (b) a witness, [REDACTED], who worked for Epstein between [REDACTED] (after the conclusion of the charged conspiracy) whom the Government said it \"may call\" at trial. The Government asserted in the Letter that the evidence collectively was, in its opinion, \"direct evidence of the crimes charged and, in the alternative, pursuant to Rule 404(b) as proof of the defendant's intent, preparation, plan, knowledge, identity, and/or absence of mistake of (sic) accident.\" Id. at 2. The Government stated it would not be moving in limine to seek the evidence's admission \"[b]ecause this evidence is admissible as direct evidence.\" Id. The Letter lacked identification of any particular purpose for these two categories of evidence and lacked any \"basis for concluding that the evidence is relevant in light of this purpose.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Also on October 11, the Government provided its anticipated trial exhibits. Even a quick review of those exhibits reflects the Government's apparent intent to offer numerous documents and other evidence that purportedly occurred after the conclusion of the charged conspiracy.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "See, e.g., GX-4-D through GX-4-K (message pads dated beginning in 2005); GX-423 (an Amazon shipment to Jeffrey Epstein of an iPhone USB lightning cable in 2013); GX-501 & 502 (financial statements from June 2007); GX-661 & 662 (flight logs from 2005-13). None of these items of evidence were mentioned in the Maxwell Rule 404(b) Letter. The Government's theory of admissibility concerning this post-2004 evidence remains unclear.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005615",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "October 11, 2021",
      "2005",
      "2013",
      "June 2007",
      "2005-13",
      "October 11"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 385",
      "Dkt. 297",
      "GX-4-D",
      "GX-4-K",
      "GX-423",
      "GX-501",
      "GX-502",
      "GX-661",
      "GX-662"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions. The redactions are likely related to sensitive information or evidence in a criminal case."
}