{
  "document_metadata": {
    "page_number": "7",
    "document_number": "24",
    "date": "July 16, 2019",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 24 Filed 07/16/19 Page 7 of 9\n\nHon. Richard M. Berman\nJuly 16, 2019\nPage 7\n\nSeventh, to the extent third-party counsel (Mr. Boies) speculated that the November 28 and December 3, 2018 payments8 were made to \"witnesses who were cooperating with us\"9 in civil litigation, he is wrong. As explained in Court, the recipients were \"long-time [Epstein] friends and employees\"10 - not putative victims - and they never cooperated with Mr. Boies. To the contrary, each invoked the Fifth Amendment and refused to testify when civilly deposed, respectively, in prior New York federal and Florida state civil proceedings. Subject to the protective orders in these proceedings, we would be pleased to provide relevant deposition transcripts.\n\nEighth, as for the Austrian passport the government trumpets, it expired 32 years ago. And the government offers nothing to suggest - and certainly no evidence - that Epstein ever used it. In any case, Epstein - an affluent member of the Jewish faith - acquired the passport in the\n\n8 7/12/19 Ltr. 11.\n9 7/15/19 Tr. 70-71.\n10 Ibid. 69.\n\nDOJ-OGR-00000451",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 24 Filed 07/16/19 Page 7 of 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Hon. Richard M. Berman\nJuly 16, 2019\nPage 7",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Seventh, to the extent third-party counsel (Mr. Boies) speculated that the November 28 and December 3, 2018 payments8 were made to \"witnesses who were cooperating with us\"9 in civil litigation, he is wrong. As explained in Court, the recipients were \"long-time [Epstein] friends and employees\"10 - not putative victims - and they never cooperated with Mr. Boies. To the contrary, each invoked the Fifth Amendment and refused to testify when civilly deposed, respectively, in prior New York federal and Florida state civil proceedings. Subject to the protective orders in these proceedings, we would be pleased to provide relevant deposition transcripts.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Eighth, as for the Austrian passport the government trumpets, it expired 32 years ago. And the government offers nothing to suggest - and certainly no evidence - that Epstein ever used it. In any case, Epstein - an affluent member of the Jewish faith - acquired the passport in the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "8 7/12/19 Ltr. 11.\n9 7/15/19 Tr. 70-71.\n10 Ibid. 69.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000451",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Richard M. Berman",
      "Mr. Boies",
      "Epstein"
    ],
    "organizations": [],
    "locations": [
      "New York",
      "Florida",
      "Austria"
    ],
    "dates": [
      "July 16, 2019",
      "November 28, 2018",
      "December 3, 2018",
      "7/12/19",
      "7/15/19"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 24",
      "DOJ-OGR-00000451"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
}