{
  "document_metadata": {
    "page_number": "7",
    "document_number": "704",
    "date": "07/12/22",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page 7 of 8\n\nfront of their friends, families, and communities. For instance, Government cooperators and confidential sources routinely express reluctance to testify and have their cooperation with the Government made public. Yet, absent a safety concern, they do so.\n\nThird, denying the defendant's motion does not implicate the defendant's constitutional rights to a fair trial or to present a defense. Although the defendant states that she has encountered resistance from potential witnesses who are afraid of \"unfavorable publicity should their names be publicly associated with Mr. Epstein,\" (Def. Letter at 3), the defendant retains the right to compulsory process. If Michelle Healy or will not testify willingly unless the Court anonymizes their identities, the defendant can compel them to testify. See Fed. R. Crim. P. 17(a). If will not testify willingly, the defendant can seek a letter rogatory. See 18 U.S.C. § 1781(a)(2). Once the witnesses take the stand, they must testify truthfully on penalty of perjury. See 18 U.S.C. § 1621. The defendant is right that she cannot compel witnesses to be interviewed away from the presence of the jury—but she has no constitutional right to do so. And the Government has the same powers and limitations. Put simply, the defendant's constitutional rights are not infringed if this Court follows the same rule as every other court in every other trial, high profile or not.\n\nIV. Conclusion\n\nFor the reasons set forth above, the Court should deny the defendant's motion.\n\n7\n\nDOJ-OGR-00011239",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 704 Filed 07/12/22 Page 7 of 8",
      "position": "header"
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    {
      "type": "printed",
      "content": "front of their friends, families, and communities. For instance, Government cooperators and confidential sources routinely express reluctance to testify and have their cooperation with the Government made public. Yet, absent a safety concern, they do so.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Third, denying the defendant's motion does not implicate the defendant's constitutional rights to a fair trial or to present a defense. Although the defendant states that she has encountered resistance from potential witnesses who are afraid of \"unfavorable publicity should their names be publicly associated with Mr. Epstein,\" (Def. Letter at 3), the defendant retains the right to compulsory process. If Michelle Healy or will not testify willingly unless the Court anonymizes their identities, the defendant can compel them to testify. See Fed. R. Crim. P. 17(a). If will not testify willingly, the defendant can seek a letter rogatory. See 18 U.S.C. § 1781(a)(2). Once the witnesses take the stand, they must testify truthfully on penalty of perjury. See 18 U.S.C. § 1621. The defendant is right that she cannot compel witnesses to be interviewed away from the presence of the jury—but she has no constitutional right to do so. And the Government has the same powers and limitations. Put simply, the defendant's constitutional rights are not infringed if this Court follows the same rule as every other court in every other trial, high profile or not.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "IV. Conclusion",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "For the reasons set forth above, the Court should deny the defendant's motion.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "7",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011239",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Michelle Healy",
      "Epstein"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "07/12/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "704",
      "DOJ-OGR-00011239"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a clear and legible text. There are no visible redactions or damage to the document."
}