{
  "document_metadata": {
    "page_number": "18 of 27",
    "document_number": "136",
    "date": "02/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 136 Filed 02/04/21 Page 18 of 27\ndifferent from the first question because it included the phrase\n\nAgain, the question was objected to. After much back and forth, the examiner asked the question giving rise to the second alleged instance of perjury: \"List all the people under the age of 18 that you interacted with at any of Jeffrey's properties?\"\n\nThis question was almost the same as the first demand for a \"list,\" but instead of\n\nthe examiner substituted the amorphous, ambiguous phrase \"interacted with.\" Ms. Maxwell had already answered that she could not \"make a list.\" The question was improper for the additional reason that \"the taking of an oral deposition pursuant to Fed. R. Civ. P. Rule 26, should not be converted in effect into an interrogatory procedure (Rule 33) or an inspection procedure (Rule 34)...\" Deep S. Oil Co of Tex v. Metro. Life Ins Co., 25 F.R.D. 81, 82 (S.D.N.Y. 1959).\n\nC. Count Six\n\nThe alleged perjury in Count Six can be broken down into three topics separated by dozens of pages of objections, argument, and colloquy (including the examiner's refusal to allow Ms. Maxwell to take a bathroom break). The topics involved\n\nAs in Count Five, the Government has selectively omitted context and objections. Exact quotes, in context, are set forth below, followed by analysis of the infirmities in each line of questioning:\n\n1. Questions About",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 136 Filed 02/04/21 Page 18 of 27",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "different from the first question because it included the phrase\n\nAgain, the question was objected to. After much back and forth, the examiner asked the question giving rise to the second alleged instance of perjury: \"List all the people under the age of 18 that you interacted with at any of Jeffrey's properties?\"\n\nThis question was almost the same as the first demand for a \"list,\" but instead of\n\nthe examiner substituted the amorphous, ambiguous phrase \"interacted with.\" Ms. Maxwell had already answered that she could not \"make a list.\" The question was improper for the additional reason that \"the taking of an oral deposition pursuant to Fed. R. Civ. P. Rule 26, should not be converted in effect into an interrogatory procedure (Rule 33) or an inspection procedure (Rule 34)...\" Deep S. Oil Co of Tex v. Metro. Life Ins Co., 25 F.R.D. 81, 82 (S.D.N.Y. 1959).",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "C. Count Six",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "The alleged perjury in Count Six can be broken down into three topics separated by dozens of pages of objections, argument, and colloquy (including the examiner's refusal to allow Ms. Maxwell to take a bathroom break). The topics involved",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "As in Count Five, the Government has selectively omitted context and objections. Exact quotes, in context, are set forth below, followed by analysis of the infirmities in each line of questioning:",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "1. Questions About",
      "position": "main content"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey",
      "Ms. Maxwell"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "02/04/21",
      "1959"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 136",
      "25 F.R.D. 81, 82",
      "DOJ-OGR-00002427"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Ms. Maxwell and Jeffrey. The text includes redactions and references to specific court rules and precedents. The document is likely a legal brief or memorandum."
}