{
  "document_metadata": {
    "page_number": "42 of 51",
    "document_number": "621",
    "date": "02/25/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 42 of 51\nextablished that the testimony would have been favorable to [her], [she has] not shown that the witnesses would have been 'key' and not peripheral.\" Id.; see also id. (\"The rule in this Circuit has long been that 'missing peripheral witnesses are not enough[.]'\" (quoting Rubin, 609 F.2d at 66)).\n\nThe defendant also claims to have suffered prejudice regarding what she calls \"critical documentary records\" that were no longer available to challenge certain Government assertions or \"test critical dates.\" (Def. Mot. at 25, 27). She specifically points to the unavailability of certain flight records, financial documents, phone records, and property records as proof of actual and substantial prejudice. (Id. at 26-29). Her unsubstantiated claims fail for at least three reasons.\n\nFirst, the defendant's motion either speculates about or lacks any suggestion of what such records would have shown. For example, the defendant argues that \"[c]ritical financial documents\" were unavailable to her. (Id. at 27). The defendant—who herself knows about the nature of the financial transactions between herself and Epstein—fails to indicate or suggest what the financial documents would have shown. The defendant also argues that property records about Epstein's homes could have rebutted Jane's testimony about the appearance of his homes at various points in time. (Id. at 28-29). But ample evidence about the appearance of Epstein's homes was offered at trial, and the defendant's motion offers no non-speculative information about what property records would specifically have provided that was absent from trial testimony and could not have been obtained another way.\n\nSecond, the defendant's \"motion does not provide any basis to conclude that the evidence, if available, would have been favorable to the [defendant].\" Berry, 2021 WL 2665585, at *2. As",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 42 of 51",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "established that the testimony would have been favorable to [her], [she has] not shown that the witnesses would have been 'key' and not peripheral.\" Id.; see also id. (\"The rule in this Circuit has long been that 'missing peripheral witnesses are not enough[.]'\" (quoting Rubin, 609 F.2d at 66)).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The defendant also claims to have suffered prejudice regarding what she calls \"critical documentary records\" that were no longer available to challenge certain Government assertions or \"test critical dates.\" (Def. Mot. at 25, 27). She specifically points to the unavailability of certain flight records, financial documents, phone records, and property records as proof of actual and substantial prejudice. (Id. at 26-29). Her unsubstantiated claims fail for at least three reasons.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "First, the defendant's motion either speculates about or lacks any suggestion of what such records would have shown. For example, the defendant argues that \"[c]ritical financial documents\" were unavailable to her. (Id. at 27). The defendant—who herself knows about the nature of the financial transactions between herself and Epstein—fails to indicate or suggest what the financial documents would have shown. The defendant also argues that property records about Epstein's homes could have rebutted Jane's testimony about the appearance of his homes at various points in time. (Id. at 28-29). But ample evidence about the appearance of Epstein's homes was offered at trial, and the defendant's motion offers no non-speculative information about what property records would specifically have provided that was absent from trial testimony and could not have been obtained another way.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Second, the defendant's \"motion does not provide any basis to conclude that the evidence, if available, would have been favorable to the [defendant].\" Berry, 2021 WL 2665585, at *2. As",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "41",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009604",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jane",
      "Epstein",
      "Rubin",
      "Berry"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "02/25/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 621",
      "609 F.2d at 66",
      "2021 WL 2665585"
    ]
  },
  "additional_notes": "The document appears to be a court filing, likely a response to a defendant's motion. The text discusses the defendant's claims of prejudice due to missing witnesses and documentary evidence. The document is well-formatted and free of significant damage or redactions."
}