{
  "document_metadata": {
    "page_number": "29",
    "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 29 of 239\ndismiss those charges improperly asks the Court to adjudicate her guilt. It is for the jury to decide whether the defendant committed perjury, and the motion should be denied. Sixth, the crimes in the indictment should be tried together, as all six counts of the indictment are logically connected and provable through overlapping evidence. The Court should not sever this case, and thereby require victims of child sexual abuse to testify at multiple trials. Seventh, the Indictment indisputably alleges each element of every offense charged and provides the defendant with ample notice of the charges against her. Eighth, the Indictment is properly pled and there is no basis to strike any portion of it as surplusage. Ninth, the defense motion to dismiss one of the conspiracy charges as multiplicitous is premature. Tenth, the defendant is not entitled to a bill of particulars or any of the other early disclosures she seeks. Finally, the use of a grand jury sitting in White Plains to return the Indictment in this case was entirely proper.\n\nBACKGROUND\n\nOn June 29, 2020, a grand jury sitting in this District returned an indictment charging the defendant in six counts. On July 2, 2020, the Federal Bureau of Investigation (\"FBI\") arrested the defendant. On July 8, 2020, a grand jury sitting in this District returned a superseding indictment (the \"Indictment\") containing the same charges, with ministerial corrections. (Dkt. No. 17). Count One of the Indictment charges the defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 371. Count Two charges the defendant with enticing a minor to travel to engage in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporting minors to participate in",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 29 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "dismiss those charges improperly asks the Court to adjudicate her guilt. It is for the jury to decide whether the defendant committed perjury, and the motion should be denied. Sixth, the crimes in the indictment should be tried together, as all six counts of the indictment are logically connected and provable through overlapping evidence. The Court should not sever this case, and thereby require victims of child sexual abuse to testify at multiple trials. Seventh, the Indictment indisputably alleges each element of every offense charged and provides the defendant with ample notice of the charges against her. Eighth, the Indictment is properly pled and there is no basis to strike any portion of it as surplusage. Ninth, the defense motion to dismiss one of the conspiracy charges as multiplicitous is premature. Tenth, the defendant is not entitled to a bill of particulars or any of the other early disclosures she seeks. Finally, the use of a grand jury sitting in White Plains to return the Indictment in this case was entirely proper.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "BACKGROUND",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On June 29, 2020, a grand jury sitting in this District returned an indictment charging the defendant in six counts. On July 2, 2020, the Federal Bureau of Investigation (\"FBI\") arrested the defendant. On July 8, 2020, a grand jury sitting in this District returned a superseding indictment (the \"Indictment\") containing the same charges, with ministerial corrections. (Dkt. No. 17). Count One of the Indictment charges the defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 371. Count Two charges the defendant with enticing a minor to travel to engage in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporting minors to participate in",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002963",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein"
    ],
    "organizations": [
      "Federal Bureau of Investigation"
    ],
    "locations": [
      "White Plains"
    ],
    "dates": [
      "June 29, 2020",
      "July 2, 2020",
      "July 8, 2020",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "Dkt. No. 17",
      "18 U.S.C. § 371",
      "18 U.S.C. §§ 2422 and 2"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 29 of 239."
}