{
  "document_metadata": {
    "page_number": "78",
    "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 78 of 239\nto the instant prosecution, is insufficient to show actual prejudice. . . . The fact that evidence may be lost or destroyed during the pre-indictment stage is inherent in any delay, no matter what the duration. Furthermore, there has been no allegation in this case that the destruction of the records was deliberate on the part of either the government or trustee.\" (internal citations omitted)).\nLastly, the defendant contends that prejudicial media reporting and inappropriate pre-trial publicity from at least 2011 through the present has resulted in prejudice to the defendant. (Def. Mot. at 14). She claims that had the Government brought charges against her between 1996 and 2011, the Government \"would have not prevailed,\" noting that the defendant's accusers would not have been \"able to conform their 'memories' to the often republished 'obvious lies.'\" (Id. at 15). This argument, like the others contained in this motion, is steeped in speculation. The defendant cites not one case in support of her argument that pre-trial publicity can ever establish actual prejudice, nor does she point to any evidence that the Government fomented such publicity dating back to 2011. To the extent the defendant is concerned about pretrial publicity, she will have the opportunity to propose an appropriate examination of potential jurors during voir dire to identify a panel of impartial jurors who have not been prejudiced by any publicity this case may have garnered.\nIn short, the defendant's complaints are nothing more than the type of self-serving, vague, speculative, and conclusory claims of prejudice that courts have consistently rejected as insufficient to warrant dismissal of charges based upon pre-indictment delay.19 The motion should therefore be denied.\n19 The defendant also complains about the Government's failure to \"provide discovery adequate to fully investigate the extent of the prejudice to Ms. Maxwell.\" (Def. Mot. 7 at 7). Among the items the defense complains about not receiving in discovery are the names and dates of birth of the Minor Victims, the specific location of any overt act, the date of any witness statements, or any corroboration of any allegation in the Indictment. (Id.). As described herein, see Section X, infra, the Government has made substantial discovery productions pursuant to Rule",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 78 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "to the instant prosecution, is insufficient to show actual prejudice. . . . The fact that evidence may be lost or destroyed during the pre-indictment stage is inherent in any delay, no matter what the duration. Furthermore, there has been no allegation in this case that the destruction of the records was deliberate on the part of either the government or trustee.\" (internal citations omitted)).\nLastly, the defendant contends that prejudicial media reporting and inappropriate pre-trial publicity from at least 2011 through the present has resulted in prejudice to the defendant. (Def. Mot. at 14). She claims that had the Government brought charges against her between 1996 and 2011, the Government \"would have not prevailed,\" noting that the defendant's accusers would not have been \"able to conform their 'memories' to the often republished 'obvious lies.'\" (Id. at 15). This argument, like the others contained in this motion, is steeped in speculation. The defendant cites not one case in support of her argument that pre-trial publicity can ever establish actual prejudice, nor does she point to any evidence that the Government fomented such publicity dating back to 2011. To the extent the defendant is concerned about pretrial publicity, she will have the opportunity to propose an appropriate examination of potential jurors during voir dire to identify a panel of impartial jurors who have not been prejudiced by any publicity this case may have garnered.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "In short, the defendant's complaints are nothing more than the type of self-serving, vague, speculative, and conclusory claims of prejudice that courts have consistently rejected as insufficient to warrant dismissal of charges based upon pre-indictment delay.19 The motion should therefore be denied.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "19 The defendant also complains about the Government's failure to \"provide discovery adequate to fully investigate the extent of the prejudice to Ms. Maxwell.\" (Def. Mot. 7 at 7). Among the items the defense complains about not receiving in discovery are the names and dates of birth of the Minor Victims, the specific location of any overt act, the date of any witness statements, or any corroboration of any allegation in the Indictment. (Id.). As described herein, see Section X, infra, the Government has made substantial discovery productions pursuant to Rule",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "51",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003012",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "1996",
      "2011",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with a footnote and some citations. There are no visible stamps or handwritten text."
}