{
  "document_metadata": {
    "page_number": "12",
    "document_number": "224",
    "date": "04/20/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 224 Filed 04/20/21 Page 12 of 17\n\nThe Giuffre v. Maxwell litigation specifically, including:\nThe circumstances surrounding the deposition.\nThe nature and character of the Giuffre's lawyers including their unethical behavior.\nThe discovery abuses by Giuffre's lawyers.\nWhy, in the context of this defamation case, the questions being posed, now the subject of the Perjury Counts, were not material including:\nApproximately 50 unresolved motions relating to the admissibility of evidence.\nThe testimony of ten to fifteen other witnesses including fact and expert witnesses.\nThe testimony of Ms. Maxwell's lawyers.\nIn sum, if the Perjury Counts are not severed, this criminal trial will be subsumed by evidence not relevant to the main charges, the Mann Act Counts, completely unrelated to the defamation case.4\nThe government suggests that these evidentiary problems can be cured by \"stipulations\" but does not propose any. It is hard to imagine the legal gymnastics necessary to accomplish any stipulations that would fix these problems. Alternatively, or perhaps with the unknown stipulations, the government suggests prejudice could be avoided by jury instructions. It is\n4 The Second Circuit has adopted an inclusionary approach to other act evidence under Rule 404(b), which allows such evidence to be admitted for any proper purpose other than to demonstrate criminal propensity. United States v. LaFlam, 369 F.3d 153, 156 (2d Cir.2004). The rule, however, is not \"a carte blanche to admit prejudicial extrinsic act evidence....\" United States v. Scott, 677 F.3d 72, 79 (2d Cir. 2012). In evaluating F.R.E. 404(b) evidence, the Court must consider whether: (1) it is offered for a proper purpose; (2) it is relevant to a material issue in dispute; and (3) its probative value is substantially outweighed by its prejudicial effect....\" LaFlam, 369 F.3d at 156. There is no proper purpose for the admission of any of the alleged perjury which occurred decades after the charges in Counts 1-4. Certainly, the government has articulated none. Ms. Maxwell's answers to the vague and objectionable questions selectively plucked from hundreds of pages of transcripts have no relevance to any material issue related to the Mann Act Counts. And, significantly, any arguable probative value is substantially outweighed by its prejudicial effect.\n8\nDOJ-OGR-00003909",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 224 Filed 04/20/21 Page 12 of 17",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Giuffre v. Maxwell litigation specifically, including:\nThe circumstances surrounding the deposition.\nThe nature and character of the Giuffre's lawyers including their unethical behavior.\nThe discovery abuses by Giuffre's lawyers.\nWhy, in the context of this defamation case, the questions being posed, now the subject of the Perjury Counts, were not material including:\nApproximately 50 unresolved motions relating to the admissibility of evidence.\nThe testimony of ten to fifteen other witnesses including fact and expert witnesses.\nThe testimony of Ms. Maxwell's lawyers.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "In sum, if the Perjury Counts are not severed, this criminal trial will be subsumed by evidence not relevant to the main charges, the Mann Act Counts, completely unrelated to the defamation case.4",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "The government suggests that these evidentiary problems can be cured by \"stipulations\" but does not propose any. It is hard to imagine the legal gymnastics necessary to accomplish any stipulations that would fix these problems. Alternatively, or perhaps with the unknown stipulations, the government suggests prejudice could be avoided by jury instructions. It is",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "4 The Second Circuit has adopted an inclusionary approach to other act evidence under Rule 404(b), which allows such evidence to be admitted for any proper purpose other than to demonstrate criminal propensity. United States v. LaFlam, 369 F.3d 153, 156 (2d Cir.2004). The rule, however, is not \"a carte blanche to admit prejudicial extrinsic act evidence....\" United States v. Scott, 677 F.3d 72, 79 (2d Cir. 2012). In evaluating F.R.E. 404(b) evidence, the Court must consider whether: (1) it is offered for a proper purpose; (2) it is relevant to a material issue in dispute; and (3) its probative value is substantially outweighed by its prejudicial effect....\" LaFlam, 369 F.3d at 156. There is no proper purpose for the admission of any of the alleged perjury which occurred decades after the charges in Counts 1-4. Certainly, the government has articulated none. Ms. Maxwell's answers to the vague and objectionable questions selectively plucked from hundreds of pages of transcripts have no relevance to any material issue related to the Mann Act Counts. And, significantly, any arguable probative value is substantially outweighed by its prejudicial effect.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "8",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003909",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Giuffre",
      "Maxwell",
      "LaFlam",
      "Scott"
    ],
    "organizations": [
      "Second Circuit"
    ],
    "locations": [],
    "dates": [
      "04/20/21",
      "2004",
      "2012"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 224",
      "DOJ-OGR-00003909"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case United States v. Maxwell. The text discusses the potential issues with the Perjury Counts and the Mann Act Counts, and the potential for prejudice in the trial. The document includes citations to case law and references to specific court rules."
}