{
  "document_metadata": {
    "page_number": "51",
    "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 51 of 84\n\nNot so. The defendant's argument entirely misunderstands the charges in the Indictment and the jury's task at trial. The defendant is charged with conspiring to transport and entice minors for the purpose of sexual abuse. The question at trial will be whether the defendant 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. The defendant's acts involving Minor Victim-3 were part of that scheme and are highly relevant to demonstrating the existence of the conspiracy and the defendant's role in the scheme. That is all that is required for evidence relating to the defendant's exploitation of Minor Victim-3 to be direct evidence of the charged offenses. The defendant is not charged with an offense under United Kingdom law, and the age of consent in the United Kingdom is irrelevant. The defendant is also not charged with any substantive offenses with respect to Minor Victim-3, and thus it makes no difference whether the defendant could have, attempted to, or did successfully transport Minor Victim-3 in violation of those statutes.12\n\nIn any event, this evidence is all admissible under Rule 404(b).13 Testimony regarding the defendant's efforts to recruit and encourage Minor Victim-3 to engage in sex acts with Epstein in the context of massages establishes that the defendant knew of Epstein's attraction to minor girls\n\n12 Indeed, there is no risk at trial that the jury will convict the defendant based on the testimony of Minor Victim-3 alone. As the Government has made clear, the jury may not convict the defendant of the conspiracy offense solely based on Minor Victim-3 due to the statute of limitations. (Gov't Opp. at 157-58, 163, Dkt. No. 204). The jury should be appropriately instructed at the conclusion of the trial.\n\n13 To the extent this evidence is properly admissible under Rule 404(b) rather than as direct evidence, the Government's detailed memorandum in opposition to the defense pretrial motions, which described theories of 404(b) admissibility (Gov't Opp. at 165-69, Dkt. No. 204), and this memorandum, filed five weeks before trial, is more than sufficient notice for the defense.\n\n50\nDOJ-OGR-00006759",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 51 of 84",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Not so. The defendant's argument entirely misunderstands the charges in the Indictment and the jury's task at trial. The defendant is charged with conspiring to transport and entice minors for the purpose of sexual abuse. The question at trial will be whether the defendant 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. The defendant's acts involving Minor Victim-3 were part of that scheme and are highly relevant to demonstrating the existence of the conspiracy and the defendant's role in the scheme. That is all that is required for evidence relating to the defendant's exploitation of Minor Victim-3 to be direct evidence of the charged offenses. The defendant is not charged with an offense under United Kingdom law, and the age of consent in the United Kingdom is irrelevant. The defendant is also not charged with any substantive offenses with respect to Minor Victim-3, and thus it makes no difference whether the defendant could have, attempted to, or did successfully transport Minor Victim-3 in violation of those statutes.12",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "In any event, this evidence is all admissible under Rule 404(b).13 Testimony regarding the defendant's efforts to recruit and encourage Minor Victim-3 to engage in sex acts with Epstein in the context of massages establishes that the defendant knew of Epstein's attraction to minor girls",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "12 Indeed, there is no risk at trial that the jury will convict the defendant based on the testimony of Minor Victim-3 alone. As the Government has made clear, the jury may not convict the defendant of the conspiracy offense solely based on Minor Victim-3 due to the statute of limitations. (Gov't Opp. at 157-58, 163, Dkt. No. 204). The jury should be appropriately instructed at the conclusion of the trial.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "13 To the extent this evidence is properly admissible under Rule 404(b) rather than as direct evidence, the Government's detailed memorandum in opposition to the defense pretrial motions, which described theories of 404(b) admissibility (Gov't Opp. at 165-69, Dkt. No. 204), and this memorandum, filed five weeks before trial, is more than sufficient notice for the defense.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "50",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006759",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Minor Victim-3"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [
      "United Kingdom"
    ],
    "dates": [
      "11/12/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "452",
      "204",
      "DOJ-OGR-00006759"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Jeffrey Epstein. The text discusses the charges against the defendant and the admissibility of certain evidence. The document is well-formatted and free of significant damage or redactions."
}