{
  "document_metadata": {
    "page_number": "5",
    "document_number": "336-3",
    "date": "09/07/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 336-3 Filed 09/07/21 Page 5 of 22\n\nATTACHMENT A\n\nDEFINITIONS\n\n1. \"You\" or \"Your\" means Brad Edwards and any owner, shareholder, partner, employee or independent contractor of Edwards Pottinger and any former owner, shareholder, partner or employee, or independent contractor of the firm. \"You\" or \"Your\" also refers to any shareholder, partner, employee or independent contractor of any other law firm with which You were employed or formally associated at the responsive time.\n\n2. \"United States Attorney\" means any employee of the office of the United States Attorney for the Southern District of New York during the relevant time period including but not limited to Amanda Kramer, Alex Rossmiller, Allison Moe, Lara Pomerantz, Maurene Comey and Andrew Rohrbach. \"United States Attorney\" also includes any employee of the Federal Bureau of Investigation.\n\n3. \"Communication\" means all forms of correspondence, including regular mail, email, text message, memorandum, or other written communication of information of any kind.\n\n4. \"Contingent Fee Agreement\" or \"Engagement Agreement\" means any writing describing the terms that You agreed to perform legal services for Annie Farmer, Maria Farmer, or .\n\n5. \"Maria Farmer Physical Evidence\" means the \"hundreds of photographs,\" \"old diaries,\" \"telephone books,\" \"Rolodexes,\" and \"mementos . . . collected from [Maria Farmer's] time with Epstein and Maxwell\" that You viewed at the home of Maria Farmer in Paducah, KY home in or about June 2016, as described in excerpts from Relentless Pursuit, attached as Exhibit A.\n\n6. \"EVCP Material\" refers to any submission to the Epstein Victim's Compensation Program made by You, including any claims on behalf of persons who have accused Jeffrey Epstein or Ghislaine Maxwell of any misconduct, any releases signed by You or Your Clients, and any compensation received by You or Your Clients. The EVCP is described in Exhibit B.\n\nINSTRUCTIONS\n\n1. Production of documents and items requested herein shall be made no later than April 1, 2021, at 1:00 p.m. Except for Items 8 and 9 below, you may provide the records electronically by that date and time to Jeffrey S. Pagliuca or by such other method as agreed upon with counsel for the subpoenaing party.\n\n2. This Request calls for the production of all responsive Documents in Your possession, custody or control without regard to the physical location of such documents.\n\n3. This Request calls for the production of all responsive Documents, regardless of the firm with which You were affiliated at the time the Document was created.\n\n4. If any Document was in your possession or control, but is no longer, state what disposition was made of said Document, the reason for the disposition, and the date of such disposition.\n\nDOJ-OGR-00005138",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 336-3 Filed 09/07/21 Page 5 of 22",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "ATTACHMENT A\n\nDEFINITIONS",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "1. \"You\" or \"Your\" means Brad Edwards and any owner, shareholder, partner, employee or independent contractor of Edwards Pottinger and any former owner, shareholder, partner or employee, or independent contractor of the firm. \"You\" or \"Your\" also refers to any shareholder, partner, employee or independent contractor of any other law firm with which You were employed or formally associated at the responsive time.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2. \"United States Attorney\" means any employee of the office of the United States Attorney for the Southern District of New York during the relevant time period including but not limited to Amanda Kramer, Alex Rossmiller, Allison Moe, Lara Pomerantz, Maurene Comey and Andrew Rohrbach. \"United States Attorney\" also includes any employee of the Federal Bureau of Investigation.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3. \"Communication\" means all forms of correspondence, including regular mail, email, text message, memorandum, or other written communication of information of any kind.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "4. \"Contingent Fee Agreement\" or \"Engagement Agreement\" means any writing describing the terms that You agreed to perform legal services for Annie Farmer, Maria Farmer, or .",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "5. \"Maria Farmer Physical Evidence\" means the \"hundreds of photographs,\" \"old diaries,\" \"telephone books,\" \"Rolodexes,\" and \"mementos . . . collected from [Maria Farmer's] time with Epstein and Maxwell\" that You viewed at the home of Maria Farmer in Paducah, KY home in or about June 2016, as described in excerpts from Relentless Pursuit, attached as Exhibit A.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "6. \"EVCP Material\" refers to any submission to the Epstein Victim's Compensation Program made by You, including any claims on behalf of persons who have accused Jeffrey Epstein or Ghislaine Maxwell of any misconduct, any releases signed by You or Your Clients, and any compensation received by You or Your Clients. The EVCP is described in Exhibit B.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "INSTRUCTIONS",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1. Production of documents and items requested herein shall be made no later than April 1, 2021, at 1:00 p.m. Except for Items 8 and 9 below, you may provide the records electronically by that date and time to Jeffrey S. Pagliuca or by such other method as agreed upon with counsel for the subpoenaing party.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2. This Request calls for the production of all responsive Documents in Your possession, custody or control without regard to the physical location of such documents.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3. This Request calls for the production of all responsive Documents, regardless of the firm with which You were affiliated at the time the Document was created.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "4. If any Document was in your possession or control, but is no longer, state what disposition was made of said Document, the reason for the disposition, and the date of such disposition.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005138",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Brad Edwards",
      "Amanda Kramer",
      "Alex Rossmiller",
      "Allison Moe",
      "Lara Pomerantz",
      "Maurene Comey",
      "Andrew Rohrbach",
      "Annie Farmer",
      "Maria Farmer",
      "Jeffrey Epstein",
      "Ghislaine Maxwell",
      "Jeffrey S. Pagliuca"
    ],
    "organizations": [
      "Edwards Pottinger",
      "United States Attorney for the Southern District of New York",
      "Federal Bureau of Investigation",
      "Epstein Victim's Compensation Program"
    ],
    "locations": [
      "Paducah, KY",
      "Southern District of New York"
    ],
    "dates": [
      "April 1, 2021",
      "09/07/21",
      "June 2016"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 336-3",
      "DOJ-OGR-00005138"
    ]
  },
  "additional_notes": "The document appears to be a court filing with definitions and instructions related to a case involving Jeffrey Epstein and Ghislaine Maxwell. The document is page 5 of 22 and has been redacted in some areas."
}