{
  "document_metadata": {
    "page_number": "53",
    "document_number": "439",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 439 Filed 11/12/21 Page 53 of 69\ngovernment has provided \"notice\" tha was a \"victim\" in this case, and has disclosed\na number of exhibits related to her - school records (GX 781-783); employment records (GX 821-22), photo (GX 332).27 It is apparent that the government hopes to prove that was a \"victim\" in the sense that she was underage when she had sex with Jeffrey Epstein, without calling her as a witness in this case. Again, if the government offers evidence that the sexual contact observed by between and Mr. Epstein amounts to \"sexual abuse\" because was underage, then such testimony would open the door to the mountains of evidence that tends to impeach that assertion.\n\nGiven the failure to specify the statements that will be elicited, the purposes for which those statements qualify as non-hearsay, depriving the defense of an opportunity to brief whether such statements open the door to credibility challenges of the accuser-declarants and , this Court should deny the motion.\n27 Tellingly, the government failed to provide an exhibit for birth certificate, but did for . See GX 11-15.",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 439 Filed 11/12/21 Page 53 of 69",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "government has provided \"notice\" tha was a \"victim\" in this case, and has disclosed\na number of exhibits related to her - school records (GX 781-783); employment records (GX 821-22), photo (GX 332).27 It is apparent that the government hopes to prove that was a \"victim\" in the sense that she was underage when she had sex with Jeffrey Epstein, without calling her as a witness in this case. Again, if the government offers evidence that the sexual contact observed by between and Mr. Epstein amounts to \"sexual abuse\" because was underage, then such testimony would open the door to the mountains of evidence that tends to impeach that assertion.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Given the failure to specify the statements that will be elicited, the purposes for which those statements qualify as non-hearsay, depriving the defense of an opportunity to brief whether such statements open the door to credibility challenges of the accuser-declarants and , this Court should deny the motion.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "27 Tellingly, the government failed to provide an exhibit for birth certificate, but did for . See GX 11-15.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "45",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006470",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/12/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "439",
      "GX 781-783",
      "GX 821-22",
      "GX 332",
      "GX 11-15"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Jeffrey Epstein. The text is mostly printed, with some redacted sections. The document is page 53 of 69."
}