{
  "document_metadata": {
    "page_number": "17",
    "document_number": "453",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 17 of 52\ndrafted by Ms. Maxwell. Compare GX 417-B, 418-B, 420-B, 420-B (all purporting to represent metadata of other emails with the author identified). But even this document, which is not at issue in this Motion, speaks to a discussion of adult women. Apparently the government thinks that discussions of adult women (aged, in the document, 35, 25, 23, and 25 years old) is a \"motive\" or \"intent\" to groom underage females. Such arguments are based on outdated stereotypes and reveal a reliance on character evidence that the Rules of Evidence specifically disallow.\n\nThis Court should reject the belated, insufficient, improper argument that the Emails are direct evidence of the charged conspiracy, should find they are propensity evidence barred by Rule 404(b) and should also exclude them under Rule 403 as more prejudicial than probative.\n\nB.\n\nThe government's proffered evidence regarding testimony and apparent plan to lay the foundation for a broad swath of government exhibits differs dramatically from the discrete set of Emails described above.\n\nThe government does not even seriously argue a non-propensity basis for the testimony of under Rule 404(b). See Resp. at 39 (\"this evidence is admissible in the alternative under Rule 404(b) for substantially the same reasons\"). Rather, they hang their hat on their argument, presented for the first time in response, that they intend to offer through her\n\n11\nDOJ-OGR-00006897",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 17 of 52",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "drafted by Ms. Maxwell. Compare GX 417-B, 418-B, 420-B, 420-B (all purporting to represent metadata of other emails with the author identified). But even this document, which is not at issue in this Motion, speaks to a discussion of adult women. Apparently the government thinks that discussions of adult women (aged, in the document, 35, 25, 23, and 25 years old) is a \"motive\" or \"intent\" to groom underage females. Such arguments are based on outdated stereotypes and reveal a reliance on character evidence that the Rules of Evidence specifically disallow.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "This Court should reject the belated, insufficient, improper argument that the Emails are direct evidence of the charged conspiracy, should find they are propensity evidence barred by Rule 404(b) and should also exclude them under Rule 403 as more prejudicial than probative.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "B.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government's proffered evidence regarding testimony and apparent plan to lay the foundation for a broad swath of government exhibits differs dramatically from the discrete set of Emails described above.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government does not even seriously argue a non-propensity basis for the testimony of under Rule 404(b). See Resp. at 39 (\"this evidence is admissible in the alternative under Rule 404(b) for substantially the same reasons\"). Rather, they hang their hat on their argument, presented for the first time in response, that they intend to offer through her",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "11",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006897",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/12/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 453",
      "GX 417-B",
      "GX 418-B",
      "GX 420-B",
      "Rule 404(b)",
      "Rule 403",
      "DOJ-OGR-00006897"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions. The text is mostly printed, with some blacked-out sections likely containing sensitive or personal information."
}