{
  "document_metadata": {
    "page_number": "33",
    "document_number": "398",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 33 of 52\nfor the purpose of engaging in unlawful sexual activity (it was not). Moreover, allowing the government to circumvent Rule 404(b) by charging \"other act\" evidence in the Indictment would swallow the rule and allow the jury to broadly consider evidence that should only be considered for a limited purpose and with an appropriate limiting instruction regarding propensity. The Court should not allow this.\nThird, the government claims that evidence can be admitted as intrinsic proof of the charged conspiracies to show Ms. Maxwell's (1) \"relationship with Epstein, including her willingness to procure teenagers to give Epstein massages,\" (2) \"knowledge of both the sexual nature of those massages and the need to procure additional victims,\" and (3) \"willingness to transport minors to further their abuse.\" Resp. at 47. The government further argues that evidence is necessary to \"complete the story\" of the charged offenses. Id. at 48-49. In its Motion, the defense cited numerous cases in this Circuit holding that evidence of other conduct involving alleged co-conspirators—even conduct that was similar to the charged offenses—was not admissible as intrinsic proof of the conspiracies if the other conduct was separate and distinct from the charged offenses. See Mot. at 9 (citing cases). The government concedes that these cases so hold and points out that these cases admitted some of the proffered evidence under Rule 404(b). Resp. at 48 n.11. This just proves the point; the admissibility of evidence should be evaluated under Rule 404(b).\nFourth, the government asserts that the defense \"misunderstands\" the law and that the government simply needs to prove that Ms. Maxwell \"took steps to provide Jeffrey Epstein with access to girls under the age of 18, knowing that Epstein intended to have sexual contact with those girls.\" Id. at 50 (emphasis added). In the government's view, it is totally irrelevant that\n27\nDOJ-OGR-00005988",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 398 Filed 10/29/21 Page 33 of 52",
      "position": "header"
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    {
      "type": "printed",
      "content": "for the purpose of engaging in unlawful sexual activity (it was not). Moreover, allowing the government to circumvent Rule 404(b) by charging \"other act\" evidence in the Indictment would swallow the rule and allow the jury to broadly consider evidence that should only be considered for a limited purpose and with an appropriate limiting instruction regarding propensity. The Court should not allow this.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Third, the government claims that evidence can be admitted as intrinsic proof of the charged conspiracies to show Ms. Maxwell's (1) \"relationship with Epstein, including her willingness to procure teenagers to give Epstein massages,\" (2) \"knowledge of both the sexual nature of those massages and the need to procure additional victims,\" and (3) \"willingness to transport minors to further their abuse.\" Resp. at 47. The government further argues that evidence is necessary to \"complete the story\" of the charged offenses. Id. at 48-49. In its Motion, the defense cited numerous cases in this Circuit holding that evidence of other conduct involving alleged co-conspirators—even conduct that was similar to the charged offenses—was not admissible as intrinsic proof of the conspiracies if the other conduct was separate and distinct from the charged offenses. See Mot. at 9 (citing cases). The government concedes that these cases so hold and points out that these cases admitted some of the proffered evidence under Rule 404(b). Resp. at 48 n.11. This just proves the point; the admissibility of evidence should be evaluated under Rule 404(b).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Fourth, the government asserts that the defense \"misunderstands\" the law and that the government simply needs to prove that Ms. Maxwell \"took steps to provide Jeffrey Epstein with access to girls under the age of 18, knowing that Epstein intended to have sexual contact with those girls.\" Id. at 50 (emphasis added). In the government's view, it is totally irrelevant that",
      "position": "middle"
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    {
      "type": "printed",
      "content": "27",
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    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005988",
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  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Jeffrey Epstein",
      "Epstein"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 398",
      "DOJ-OGR-00005988"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, with discussions around the admissibility of certain evidence under Rule 404(b). The text is mostly printed, with no visible handwriting or stamps. The document is from a legal proceeding and contains legal terminology and references to specific court rules and cases."
}