{
  "document_metadata": {
    "page_number": "5",
    "document_number": "492",
    "date": "11/22/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 5 of 13\nPage 5\ncharged in the Indictment. But even if it is not, it is certainly admissible under Rule 404(b).\nA. Direct Evidence\nAs the Government argued in its motion, evidence relating to Minor Victim-3 is direct evidence of the Mann Act conspiracies. The defendant's conduct regarding Minor Victim-3 overlaps in time and place with the other Minor Victims charged in the Mann Act conspiracies:\nCounts One and Three charge conduct from 1994 to 2004 in New York and Palm Beach, and Minor Victim-3 began giving Epstein sexualized massages in 1994, traveling to meet Epstein and the defendant in both New York and Palm Beach. The Government expects the defendant's relationship with Epstein to be a \"critical factual dispute\"—specifically, whether that relationship included conspiring with him and aiding or abetting Epstein's sex crimes. United States v. Robinson, 702 F.3d 22, 37 (2d Cir. 2012). Minor Victim-3's testimony will help establish that it did.\nEvidence relating to Minor Victim-3 also \"fills in a narrative\" about \"why [the defendant] took actions to\" arrange sexualized massages. United States v. Rodriguez, 727 F. App'x 24, 26 (2d Cir. 2018) (summary order).\nFinally, evidence related to Minor Victim-3 is direct evidence as corroboration for the other three Minor Victims. Those Minor Victims will describe a conspiracy that operated to recruit girls for the purposes of massage, groom them, and transform the massages into sexual encounters. The conspirators then traveled with the girls or invited girls to travel, and asked the girls to find others for Epstein.\nDOJ-OGR-00007422",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 5 of 13",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 5",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "charged in the Indictment. But even if it is not, it is certainly admissible under Rule 404(b).\nA. Direct Evidence\nAs the Government argued in its motion, evidence relating to Minor Victim-3 is direct evidence of the Mann Act conspiracies. The defendant's conduct regarding Minor Victim-3 overlaps in time and place with the other Minor Victims charged in the Mann Act conspiracies:\nCounts One and Three charge conduct from 1994 to 2004 in New York and Palm Beach, and Minor Victim-3 began giving Epstein sexualized massages in 1994, traveling to meet Epstein and the defendant in both New York and Palm Beach. The Government expects the defendant's relationship with Epstein to be a \"critical factual dispute\"—specifically, whether that relationship included conspiring with him and aiding or abetting Epstein's sex crimes. United States v. Robinson, 702 F.3d 22, 37 (2d Cir. 2012). Minor Victim-3's testimony will help establish that it did.\nEvidence relating to Minor Victim-3 also \"fills in a narrative\" about \"why [the defendant] took actions to\" arrange sexualized massages. United States v. Rodriguez, 727 F. App'x 24, 26 (2d Cir. 2018) (summary order).\nFinally, evidence related to Minor Victim-3 is direct evidence as corroboration for the other three Minor Victims. Those Minor Victims will describe a conspiracy that operated to recruit girls for the purposes of massage, groom them, and transform the massages into sexual encounters. The conspirators then traveled with the girls or invited girls to travel, and asked the girls to find others for Epstein.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00007422",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [
      "New York",
      "Palm Beach"
    ],
    "dates": [
      "11/22/21",
      "1994",
      "2004"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 492",
      "DOJ-OGR-00007422"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving Jeffrey Epstein. The text discusses the admissibility of evidence related to Minor Victim-3 and its relevance to the Mann Act conspiracies. There are no visible redactions or damage to the document."
}