{
  "document_metadata": {
    "page_number": "11",
    "document_number": "136",
    "date": "02/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 136 Filed 02/04/21 Page 11 of 27\n\nIn mid-2016 after his second deposition, according to media reports, Giuffre's lawyers urged the Government to charge Ms. Maxwell with perjury based on her testimony.5 It is unclear how the attorneys could have done so without violating the protective order, which forbade them from sharing the contents of these “confidential” depositions with law enforcement.\n\nII. The Indictment\n\nCount Five of the Indictment alleges that Ms. Maxwell made two false statements during the first deposition in April 2016. Count 5 alleges that the following italicized testimony by Ms. Maxwell was both material and false:\n\nQ. Did Jeffrey Epstein have a scheme to recruit underage girls for sexual massages? If you know.\n\nA. I don't know what you're talking about.\n\nQ. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties?\n\nA. I'm not aware of anybody that I interacted with, other than obviously [the plaintiff] who was 17 at this point.\n\nIndictment ¶ 21.\n\nCount Six alleges that Ms. Maxwell gave false testimony during a subsequent deposition in the same action in July 2016. Count Six alleges that the following italicized testimony from that deposition was both material and false:\n\nQ. Were you aware of the presence of sex toys or devices used in sexual activities in Mr. Epstein's Palm Beach house?\n\nA. No, not that I recall. . . .\n\nQ. Do you know whether Mr. Epstein possessed sex toys or devices used in sexual activities?\n\n5 Brown, supra n.4.\n\n6\nDOJ-OGR-00002420",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 136 Filed 02/04/21 Page 11 of 27",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "In mid-2016 after his second deposition, according to media reports, Giuffre's lawyers urged the Government to charge Ms. Maxwell with perjury based on her testimony.5 It is unclear how the attorneys could have done so without violating the protective order, which forbade them from sharing the contents of these “confidential” depositions with law enforcement.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "II. The Indictment",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Count Five of the Indictment alleges that Ms. Maxwell made two false statements during the first deposition in April 2016. Count 5 alleges that the following italicized testimony by Ms. Maxwell was both material and false:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Q. Did Jeffrey Epstein have a scheme to recruit underage girls for sexual massages? If you know.\nA. I don't know what you're talking about.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties?\nA. I'm not aware of anybody that I interacted with, other than obviously [the plaintiff] who was 17 at this point.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Indictment ¶ 21.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Count Six alleges that Ms. Maxwell gave false testimony during a subsequent deposition in the same action in July 2016. Count Six alleges that the following italicized testimony from that deposition was both material and false:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Q. Were you aware of the presence of sex toys or devices used in sexual activities in Mr. Epstein's Palm Beach house?\nA. No, not that I recall. . . .",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Q. Do you know whether Mr. Epstein possessed sex toys or devices used in sexual activities?",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "5 Brown, supra n.4.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "6",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002420",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Giuffre",
      "Maxwell",
      "Jeffrey Epstein",
      "Brown"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [
      "Palm Beach"
    ],
    "dates": [
      "mid-2016",
      "April 2016",
      "July 2016",
      "02/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 136",
      "Indictment ¶ 21",
      "DOJ-OGR-00002420"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ghislaine Maxwell, with references to Jeffrey Epstein and various legal proceedings. The text includes quoted testimony from depositions and references to specific counts in an indictment."
}