{
  "document_metadata": {
    "page_number": "11",
    "document_number": "120",
    "date": "01/25/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 120 Filed 01/25/21 Page 11 of 19\naccusers were not part of the subject matter of the defamation action, nor were they deposed as witnesses in that case. The Perjury Counts therefore are not “of the same or similar character,” nor are they “based on the same act or transaction” as the Mann Act Counts and cannot be joined. Fed. R. Crim. P. 8(a); see Halper, 590 F.2d at 430 (temporally and factually distinct Medicaid fraud and tax evasion offenses were not based on same transaction, nor were they “of the same or similar character” simply because both involved attempts to submit false information to government agencies).\nFurthermore, the perjury offenses purportedly occurred more than twenty years after the offenses alleged in the Mann Act Counts. There is no allegation that Ms. Maxwell continued conspiring with Epstein, or engaged in any misconduct at all, in the intervening time period. In fact, the government did not charge Ms. Maxwell in connection with the investigation that led to Epstein’s Non-Prosecution Agreement in 2007, or in its 2019 indictment of Epstein, which charged Epstein with sex trafficking offenses from 2002-2005. Joinder is improper when the offenses are separated by such a significant time period and do not relate to each other. See Martinez, 1993 WL 322768, at *8-*9 (joinder of firearm possession and narcotics conspiracy counts improper under Rule 8(a) where firearm was seized in different location over four months after narcotics conspiracy ended “under circumstances having no bearing on either the alleged narcotics conspiracy, or any of [defendant’s] coconspirators”); Brown, 2008 WL 161146, at *5 (joinder improper under Rule 8(a) where a firearm possession count was unrelated “both physically and temporally” to narcotics counts in indictment (emphasis original)).\nThe Perjury Counts and the Mann Act Counts are also not “parts of a common scheme or plan.” Fed. R. Crim. P. 8(a). As a general matter, perjury, false statements, and obstruction of justice offenses are sufficiently connected to and appropriately joined with underlying 7\nDOJ-OGR-00002289",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 120 Filed 01/25/21 Page 11 of 19",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "accusers were not part of the subject matter of the defamation action, nor were they deposed as witnesses in that case. The Perjury Counts therefore are not “of the same or similar character,” nor are they “based on the same act or transaction” as the Mann Act Counts and cannot be joined. Fed. R. Crim. P. 8(a); see Halper, 590 F.2d at 430 (temporally and factually distinct Medicaid fraud and tax evasion offenses were not based on same transaction, nor were they “of the same or similar character” simply because both involved attempts to submit false information to government agencies).",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Furthermore, the perjury offenses purportedly occurred more than twenty years after the offenses alleged in the Mann Act Counts. There is no allegation that Ms. Maxwell continued conspiring with Epstein, or engaged in any misconduct at all, in the intervening time period. In fact, the government did not charge Ms. Maxwell in connection with the investigation that led to Epstein’s Non-Prosecution Agreement in 2007, or in its 2019 indictment of Epstein, which charged Epstein with sex trafficking offenses from 2002-2005. Joinder is improper when the offenses are separated by such a significant time period and do not relate to each other. See Martinez, 1993 WL 322768, at *8-*9 (joinder of firearm possession and narcotics conspiracy counts improper under Rule 8(a) where firearm was seized in different location over four months after narcotics conspiracy ended “under circumstances having no bearing on either the alleged narcotics conspiracy, or any of [defendant’s] coconspirators”); Brown, 2008 WL 161146, at *5 (joinder improper under Rule 8(a) where a firearm possession count was unrelated “both physically and temporally” to narcotics counts in indictment (emphasis original)).",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "The Perjury Counts and the Mann Act Counts are also not “parts of a common scheme or plan.” Fed. R. Crim. P. 8(a). As a general matter, perjury, false statements, and obstruction of justice offenses are sufficiently connected to and appropriately joined with underlying",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "7",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002289",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Epstein"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "01/25/21",
      "2007",
      "2019",
      "2002",
      "2005"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-AJN",
      "Document 120",
      "DOJ-OGR-00002289"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, discussing the joinder of perjury counts and Mann Act counts. The text is printed and there are no visible stamps or handwritten notes."
}