{
  "document_metadata": {
    "page_number": "7",
    "document_number": "706",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 706 Filed 07/12/22 Page 7 of 12 York when she was 17 to attend Professional Children's School. (Tr. 349). Jane's sexual activity when she was an adult is entirely collateral to this case. Consistent with Rule 412, the parties could not have offered independent evidence about who else participated in Jane's sexual activity over the age of consent. See Dore, 2013 WL 3965281, at *6 (defining \"matters which are not collateral\" as \"those matters which are relevant to the issues in the case and could be independently proven.\"). Accordingly, as the Government explained as part of the litigation over Rule 412, the Government offered only brief testimony on direct about Jane's relationships after the age of consent in order to conclude the narrative. (See 11/10/21 Tr. at 160). Specifically, the Government asked about five questions establishing that, after Jane moved to New York and turned 18, she spent time with the defendant and Epstein and continued engaging in sexualized massages. (Tr. 349-50). The defendant proposes to do something quite different. The anticipated testimony is, at least in part, an attempt to substantively impeach Jane on the identities of individuals with whom she had adult sexual contact. Both are not relevant or subjects of independent proof in this case—they are collateral. Third, even if the anticipated testimony did impeach Jane, and even if the testimony were about a non-collateral matter, it is impeachment by contradiction of a fact elicited on cross-examination. This is precisely the sort of impeachment that the rules are intended to prohibit. Absent Jane's testimony on cross, it would be irrelevant and improper for the defendant to call witnesses to say that they did not have sexual activity with Jane and the defendant. Through 7 DOJ-OGR-00011259",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 706 Filed 07/12/22 Page 7 of 12",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "York when she was 17 to attend Professional Children's School. (Tr. 349). Jane's sexual activity when she was an adult is entirely collateral to this case. Consistent with Rule 412, the parties could not have offered independent evidence about who else participated in Jane's sexual activity over the age of consent. See Dore, 2013 WL 3965281, at *6 (defining \"matters which are not collateral\" as \"those matters which are relevant to the issues in the case and could be independently proven.\"). Accordingly, as the Government explained as part of the litigation over Rule 412, the Government offered only brief testimony on direct about Jane's relationships after the age of consent in order to conclude the narrative. (See 11/10/21 Tr. at 160). Specifically, the Government asked about five questions establishing that, after Jane moved to New York and turned 18, she spent time with the defendant and Epstein and continued engaging in sexualized massages. (Tr. 349-50).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The defendant proposes to do something quite different. The anticipated testimony is, at least in part, an attempt to substantively impeach Jane on the identities of individuals with whom she had adult sexual contact.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Both are not relevant or subjects of independent proof in this case—they are collateral.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Third, even if the anticipated testimony did impeach Jane, and even if the testimony were about a non-collateral matter, it is impeachment by contradiction of a fact elicited on cross-examination. This is precisely the sort of impeachment that the rules are intended to prohibit. Absent Jane's testimony on cross, it would be irrelevant and improper for the defendant to call witnesses to say that they did not have sexual activity with Jane and the defendant. Through",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "7",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011259",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jane",
      "Epstein"
    ],
    "organizations": [],
    "locations": [
      "New York",
      "Professional Children's School"
    ],
    "dates": [
      "11/10/21",
      "07/12/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "706",
      "2013 WL 3965281",
      "DOJ-OGR-00011259"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text discusses the admissibility of certain testimony under Rule 412. There are no visible redactions or damage to the document."
}