{
  "document_metadata": {
    "page_number": "80 of 84",
    "document_number": "452",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 80 of 84\n\nWitnesses may also reference \"victims.\" But the only witness the Government expects to use the term \"victim\" is its expert, Dr. Rocchio. And Dr. Rocchio will not be testifying about the defendant or the Minor Victims in this case, but about victims of sexual abuse generally. Accordingly, she is not vouching for the credibility of anyone in this case, or presuming anything about the truth or falsity of any accusations.\n\nTo the extent other Government witnesses use the term \"victim,\" however, it would not be prejudicial to the defense. The limitation on improper vouching applies to the prosecutor, not to Government witnesses, as even one of the defendant's cases acknowledges. See Jackson v. State, 600 A.2d 21, 25 (De. 1991) (\"The opinion does not state, nor does it imply, that the use of the term 'victim' by witnesses, as a term of art or in common parlance, is a basis for objection.\"). In particular, some of the witnesses who may use the word \"victim\" are the Minor Victims themselves, who are testifying about their subjective experiences. It is not prejudicial to the defense for someone who considers herself a victim to testify as much.22\n\nHere, as with other motions, the defendant requests an extraordinary order not seen in other cases in this District. That request lacks merit, and the Court should deny it.\n\nB. Evidence of Rape\n\nThe Government expects that at least one minor victim may describe being raped by Jeffrey Epstein. If that testimony is offered, it is directly relevant to issues before the jury. The defendant and Epstein are charged with transporting minors, enticing minors, or trafficking minors with the\n\n22 The Government defers to the Court on how it would like to refer to the Minor Victims. It notes, however, that \"Accuser\" is an alternative that is prejudicial to the Government.\n\n79\n\nDOJ-OGR-00006788",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 80 of 84",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Witnesses may also reference \"victims.\" But the only witness the Government expects to use the term \"victim\" is its expert, Dr. Rocchio. And Dr. Rocchio will not be testifying about the defendant or the Minor Victims in this case, but about victims of sexual abuse generally. Accordingly, she is not vouching for the credibility of anyone in this case, or presuming anything about the truth or falsity of any accusations.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "To the extent other Government witnesses use the term \"victim,\" however, it would not be prejudicial to the defense. The limitation on improper vouching applies to the prosecutor, not to Government witnesses, as even one of the defendant's cases acknowledges. See Jackson v. State, 600 A.2d 21, 25 (De. 1991) (\"The opinion does not state, nor does it imply, that the use of the term 'victim' by witnesses, as a term of art or in common parlance, is a basis for objection.\"). In particular, some of the witnesses who may use the word \"victim\" are the Minor Victims themselves, who are testifying about their subjective experiences. It is not prejudicial to the defense for someone who considers herself a victim to testify as much.22",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Here, as with other motions, the defendant requests an extraordinary order not seen in other cases in this District. That request lacks merit, and the Court should deny it.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "B. Evidence of Rape",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government expects that at least one minor victim may describe being raped by Jeffrey Epstein. If that testimony is offered, it is directly relevant to issues before the jury. The defendant and Epstein are charged with transporting minors, enticing minors, or trafficking minors with the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "22 The Government defers to the Court on how it would like to refer to the Minor Victims. It notes, however, that \"Accuser\" is an alternative that is prejudicial to the Government.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "79",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006788",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Dr. Rocchio",
      "Jeffrey Epstein"
    ],
    "organizations": [],
    "locations": [
      "District"
    ],
    "dates": [
      "11/12/21",
      "1991"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 452",
      "DOJ-OGR-00006788",
      "600 A.2d 21"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving Jeffrey Epstein. The text discusses the use of the term 'victim' in the context of witness testimony and the relevance of evidence related to rape. The document is well-formatted and free of significant damage or redactions."
}