{
  "document_metadata": {
    "page_number": "19",
    "document_number": "732",
    "date": "07/14/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 732 Filed 07/14/22 Page 19 of 25\nThe Honorable Alison J. Nathan November 22, 2021 Page 19\nIn any case, there are several reasons that concerns about confidentiality should not weigh heavily here. First, the EVCP imposes no confidentiality requirement on the accusers, who are free to discuss their submissions to and communications with the EVCP. Protocol, p 9 (\"Individual claimants are not bound through the Program by any rules of confidentiality.\"). In turn, because Ms. Maxwell can compel her accusers to testify about their submissions to and communications with the EVCP, see U.S. Const. amend. VI, there is no reason to prevent Ms. Maxwell from subpoenaing the submissions and communications themselves. Again, Ms. Maxwell is not required to accept her accusers' assurances that the story they are telling the jury is the same they told to the EVCP.\nMore to the point, the accusers have repeatedly exercised their freedom to discuss the alleged abuse. Three of the four have filed public lawsuits against Mr. Epstein and/or Ms. Maxwell, and they have repeatedly publicized their claims. The accusers cannot with a straight face claim this information is confidential. There's no putting the horse back in the barn.\nFor example, [REDACTED]",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 732 Filed 07/14/22 Page 19 of 25",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan November 22, 2021 Page 19",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "In any case, there are several reasons that concerns about confidentiality should not weigh heavily here. First, the EVCP imposes no confidentiality requirement on the accusers, who are free to discuss their submissions to and communications with the EVCP. Protocol, p 9 (\"Individual claimants are not bound through the Program by any rules of confidentiality.\"). In turn, because Ms. Maxwell can compel her accusers to testify about their submissions to and communications with the EVCP, see U.S. Const. amend. VI, there is no reason to prevent Ms. Maxwell from subpoenaing the submissions and communications themselves. Again, Ms. Maxwell is not required to accept her accusers' assurances that the story they are telling the jury is the same they told to the EVCP.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "More to the point, the accusers have repeatedly exercised their freedom to discuss the alleged abuse. Three of the four have filed public lawsuits against Mr. Epstein and/or Ms. Maxwell, and they have repeatedly publicized their claims. The accusers cannot with a straight face claim this information is confidential. There's no putting the horse back in the barn.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "For example, [REDACTED]",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011442",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell",
      "Mr. Epstein"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "November 22, 2021",
      "07/14/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "732",
      "DOJ-OGR-00011442"
    ]
  },
  "additional_notes": "The document contains redactions, likely due to sensitive information being discussed in the context of a court case involving Ms. Maxwell and Mr. Epstein."
}