{
  "document_metadata": {
    "page_number": "4",
    "document_number": "391",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 391 Filed 10/29/21 Page 4 of 11\n\nINTRODUCTION\n\nThe S2 Indictment alleges that Ms. Maxwell committed the charged crimes between 1994 and 2004. Accusers -1, -2 and -3 purportedly were abused between 1994 and 1997. Accuser 3 is alleged, in the Indictment, to have had contact with Jeffrey Epstein between 2001 and 2004,\n\nThe Government has listed a series of exhibits allegedly obtained during an October 2005 search of Epstein's Palm Beach residence, 358 El Brillo Way. The Court should prohibit the introduction of any item seized during the search because of serious questions about how and where the evidence was maintained, the lack of any authenticating witness, and the lack of relevance to the charges against Ms. Maxwell.\n\nI. The Palm Beach Investigation\n\nMs. Maxwell was never a target or focus of any investigation undertaken by the Palm Beach Police Department, ever. Not one of the witnesses contacted during the investigation identified Ms. Maxwell as a person who recruited them, had contact with them, or instructed them to do anything with Epstein.\n\nThe reports from the Palm Beach Police Department reflect that Officer received an anonymous complaint about an unidentified male on March 14, 2005. Officer began an investigation that, six months later, was turned over to officer Joseph Recarey. Officer investigative efforts centered on an alleged victim according to the police reports, was contacted at her school as a result of a concern by her stepmother. When questioned at the school, denied any sexual contact with any adult male. Later she acknowledged having sexual contact with Epstein and also told the police that she told Epstein that she was 18 years old. She indicated that she met Epstein through an individual named and also",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 391 Filed 10/29/21 Page 4 of 11",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "INTRODUCTION",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The S2 Indictment alleges that Ms. Maxwell committed the charged crimes between 1994 and 2004. Accusers -1, -2 and -3 purportedly were abused between 1994 and 1997. Accuser 3 is alleged, in the Indictment, to have had contact with Jeffrey Epstein between 2001 and 2004,",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government has listed a series of exhibits allegedly obtained during an October 2005 search of Epstein's Palm Beach residence, 358 El Brillo Way. The Court should prohibit the introduction of any item seized during the search because of serious questions about how and where the evidence was maintained, the lack of any authenticating witness, and the lack of relevance to the charges against Ms. Maxwell.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I. The Palm Beach Investigation",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell was never a target or focus of any investigation undertaken by the Palm Beach Police Department, ever. Not one of the witnesses contacted during the investigation identified Ms. Maxwell as a person who recruited them, had contact with them, or instructed them to do anything with Epstein.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The reports from the Palm Beach Police Department reflect that Officer received an anonymous complaint about an unidentified male on March 14, 2005. Officer began an investigation that, six months later, was turned over to officer Joseph Recarey. Officer investigative efforts centered on an alleged victim according to the police reports, was contacted at her school as a result of a concern by her stepmother. When questioned at the school, denied any sexual contact with any adult male. Later she acknowledged having sexual contact with Epstein and also told the police that she told Epstein that she was 18 years old. She indicated that she met Epstein through an individual named and also",
      "position": "bottom"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Jeffrey Epstein",
      "Joseph Recarey"
    ],
    "organizations": [
      "Palm Beach Police Department"
    ],
    "locations": [
      "Palm Beach",
      "El Brillo Way"
    ],
    "dates": [
      "1994",
      "2004",
      "1997",
      "2001",
      "2005",
      "March 14, 2005",
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 391"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ms. Maxwell. There are several redacted names and phrases throughout the text."
}