{
  "document_metadata": {
    "page_number": "2",
    "document_number": "544",
    "date": "December 14, 2021",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 544 Filed 12/14/21 Page 2 of 9\nThe Honorable Alison J. Nathan\nDecember 13, 2021\nPage 2\nattorneys themselves and agents of the government, and all are relevant to show how and why\nMs. Maxwell's accusers came to cooperate with the prosecution and testify against Ms. Maxwell.\nThe questions are relevant to motive and bias, and because the answers are not privileged, this\nCourt should permit Ms. Maxwell to call Mr. Scarola, Mr. Edwards, and Mr. Glassman as\nwitnesses.\nDespite this Court's invitation, the government refused to stipulate to the testimony Ms.\nMaxwell seeks from Mr. Glassman. In an effort to avoid a dispute, Ms. Maxwell also inquired\nwhether the government would be willing to stipulate as to Mr. Scarola's and Mr. Edwards'\ntestimony. Without disputing Ms. Maxwell's contention that their testimony is not shielded by\nthe attorney-client privilege, the government nonetheless again refused to stipulate.\nA. Jack Scarola\nMs. Maxwell anticipates that Mr. Scarola would be questioned on the following non-\nprivileged topics, which primarily relate to his acting as a conduit between Carolyn and the\ngovernment. All the information Ms. Maxwell seeks to elicit taken from government 3500\ndisclosures about Carolyn. The essence of the testimony is the following:\n- Mr. Scarola is an attorney licensed to practice law in the state of Florida.\n- Mr. Scarola represented Carolyn in a civil lawsuit against Mr. Epstein and Sarah\nKellen in 2008 and 2009.\n- Mr. Scarola sent an email to Assistant United States Attorney Rossmiller in August\n2019, copying other attorneys who represented alleged victims of Jeffrey Epstein,\nincluding Robert C. Josefsberg and Mr. Edwards.\nDOJ-OGR-00008365",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 544 Filed 12/14/21 Page 2 of 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nDecember 13, 2021\nPage 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "attorneys themselves and agents of the government, and all are relevant to show how and why\nMs. Maxwell's accusers came to cooperate with the prosecution and testify against Ms. Maxwell.\nThe questions are relevant to motive and bias, and because the answers are not privileged, this\nCourt should permit Ms. Maxwell to call Mr. Scarola, Mr. Edwards, and Mr. Glassman as\nwitnesses.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Despite this Court's invitation, the government refused to stipulate to the testimony Ms.\nMaxwell seeks from Mr. Glassman. In an effort to avoid a dispute, Ms. Maxwell also inquired\nwhether the government would be willing to stipulate as to Mr. Scarola's and Mr. Edwards'\ntestimony. Without disputing Ms. Maxwell's contention that their testimony is not shielded by\nthe attorney-client privilege, the government nonetheless again refused to stipulate.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "A. Jack Scarola\nMs. Maxwell anticipates that Mr. Scarola would be questioned on the following non-\nprivileged topics, which primarily relate to his acting as a conduit between Carolyn and the\ngovernment. All the information Ms. Maxwell seeks to elicit taken from government 3500\ndisclosures about Carolyn. The essence of the testimony is the following:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "- Mr. Scarola is an attorney licensed to practice law in the state of Florida.\n- Mr. Scarola represented Carolyn in a civil lawsuit against Mr. Epstein and Sarah\nKellen in 2008 and 2009.\n- Mr. Scarola sent an email to Assistant United States Attorney Rossmiller in August\n2019, copying other attorneys who represented alleged victims of Jeffrey Epstein,\nincluding Robert C. Josefsberg and Mr. Edwards.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008365",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell",
      "Mr. Scarola",
      "Mr. Edwards",
      "Mr. Glassman",
      "Carolyn",
      "Mr. Epstein",
      "Sarah Kellen",
      "Rossmiller",
      "Jeffrey Epstein",
      "Robert C. Josefsberg"
    ],
    "organizations": [],
    "locations": [
      "Florida"
    ],
    "dates": [
      "December 13, 2021",
      "December 14, 2021",
      "2008",
      "2009",
      "August 2019"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "544",
      "DOJ-OGR-00008365"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, with references to various individuals and events connected to Jeffrey Epstein. The text is well-formatted and clear, with no visible redactions or damage."
}