{
  "document_metadata": {
    "page_number": "26 of 40",
    "document_number": "440",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 440 Filed 11/12/21 Page 26 of 40\n\nUnited States v. Miles, 748 F.3d 485, 489 (2d Cir. 2014) (per curiam) (citation and internal quotation marks omitted).\n\nIt is elementary that “the Government is not on trial in this case, and the jury will not be asked to pass on the adequacy of its investigation.” United States v. Carton, No. 17 Cr. 680 (CM), 2018 WL 5818107, at *3 (S.D.N.Y. Oct. 19, 2018). The issue before the jury is simply whether, “in light of [the] evidence or lack of evidence, the jury [is] convinced beyond a reasonable doubt that the defendant was guilty of the crimes with which [she is] charged.” United States v. Saldarriaga, 204 F.3d 50, 52 (2d Cir. 2000) (per curiam). Accordingly, there is no basis to offer evidence about why the Government or the USAO-SDFL opened their respective investigations, how they resolved those investigations, or the death of Jeffrey Epstein. These issues simply do not relate to the defendant’s guilt or innocence of the charged crimes. See United States v. Duncan, No. 18 Cr. 289 (SHS), 2019 WL 2210663, at *3 (S.D.N.Y. May 22, 2019) (“The length of the investigation, the investigative techniques used, and the fact that [the defendant] was not initially a target of the investigation are all irrelevant pursuant to this principle.”); United States v. Aleynikov, 785 F. Supp. 2d 46, 65 (S.D.N.Y. 2011) (“As a general matter, the quality and scope of the Government’s investigation are not appropriate lines of examination . . . .”), rev’d on other grounds, 676 F.3d 71 (2d Cir. 2012).\n\nThe defense argues that they are free to offer whatever evidence they like in order to challenge the “thoroughness and even the good faith of the [government’s] investigation.” (Def. Opp. at 32 (quoting Kyles v. Whitley, 514 U.S. 419, 445 (1995)). In support, the defense cites three decades-old cases, none from this Circuit or any district in this Circuit. All arise under very\n\n25\n\nDOJ-OGR-00006542",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 440 Filed 11/12/21 Page 26 of 40",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "United States v. Miles, 748 F.3d 485, 489 (2d Cir. 2014) (per curiam) (citation and internal quotation marks omitted).\n\nIt is elementary that “the Government is not on trial in this case, and the jury will not be asked to pass on the adequacy of its investigation.” United States v. Carton, No. 17 Cr. 680 (CM), 2018 WL 5818107, at *3 (S.D.N.Y. Oct. 19, 2018). The issue before the jury is simply whether, “in light of [the] evidence or lack of evidence, the jury [is] convinced beyond a reasonable doubt that the defendant was guilty of the crimes with which [she is] charged.” United States v. Saldarriaga, 204 F.3d 50, 52 (2d Cir. 2000) (per curiam). Accordingly, there is no basis to offer evidence about why the Government or the USAO-SDFL opened their respective investigations, how they resolved those investigations, or the death of Jeffrey Epstein. These issues simply do not relate to the defendant’s guilt or innocence of the charged crimes. See United States v. Duncan, No. 18 Cr. 289 (SHS), 2019 WL 2210663, at *3 (S.D.N.Y. May 22, 2019) (“The length of the investigation, the investigative techniques used, and the fact that [the defendant] was not initially a target of the investigation are all irrelevant pursuant to this principle.”); United States v. Aleynikov, 785 F. Supp. 2d 46, 65 (S.D.N.Y. 2011) (“As a general matter, the quality and scope of the Government’s investigation are not appropriate lines of examination . . . .”), rev’d on other grounds, 676 F.3d 71 (2d Cir. 2012).\n\nThe defense argues that they are free to offer whatever evidence they like in order to challenge the “thoroughness and even the good faith of the [government’s] investigation.” (Def. Opp. at 32 (quoting Kyles v. Whitley, 514 U.S. 419, 445 (1995)). In support, the defense cites three decades-old cases, none from this Circuit or any district in this Circuit. All arise under very",
      "position": "main content"
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    {
      "type": "printed",
      "content": "25",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00006542",
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  ],
  "entities": {
    "people": [
      "Jeffrey Epstein"
    ],
    "organizations": [
      "USAO-SDFL",
      "DOJ"
    ],
    "locations": [
      "S.D.N.Y.",
      "2d Cir."
    ],
    "dates": [
      "11/12/21",
      "Oct. 19, 2018",
      "May 22, 2019",
      "1995"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 440",
      "No. 17 Cr. 680 (CM)",
      "No. 18 Cr. 289 (SHS)",
      "DOJ-OGR-00006542"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}