{
  "document_metadata": {
    "page_number": "7",
    "document_number": "544",
    "date": "December 13, 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 7 of 9\nThe Honorable Alison J. Nathan\nDecember 13, 2021\nPage 7\nRobert Glassman\nMs. Maxwell has already briefed why the attorney-client privilege does not protect Mr. Glassman from having to testify that he told the government that he told Jane it would \"help her case\" if she cooperated with the government and testified against Ms. Maxwell. Dec. 3, 2021 Maxwell Letter re Attorney Glassman. Mr. Glassman's statement to Jane was not intended to be confidential and was not in fact maintained as confidential. Id. But even if the privilege did apply, it was waived when Mr. Glassman communicated the statement to the government. Id.\nThere is a second category of relevant and non-privileged testimony Mr. Glassman has to offer. Jane claimed to remember certain events happening in 1994 because that was the year Mr. Epstein took her to see the Broadway production of The Lion King. As the attached email exchange between AUSA and Mr. Edwards shows, the government quickly recognized a problem with Jane's story because The Lion King did not premiere on Broadway until 1997. Ex. 1 (3509- 010). AUSA Rossmiller and Mr. Glassman then exchanged emails in which AUSA Rossmiller tried to massage the problem and not-so-subtly invited Jane to change her story to say that she had actually seen The Lion King movie, not the play. But Jane, through Mr. Glassman, doubled down, saying in response to AUSA Rossmiller's email she saw the Broadway production of The Lion King, not the movie:\nBroadway play... Epstein bragged about being good friends with Julie Taymor, and we had amazing first row mezzanine seats they she had apparently given him.\nEx. 1.\nThere is nothing privileged about this evidence. At the request of AUSA Rossmiller, Mr. Glassman went back to Jane about her The Lion King story. Knowing that the request came from the government, Jane stuck to her story, and Mr. Glassman communicated that response to the government.\nDOJ-OGR-00008370",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 544 Filed 12/14/21 Page 7 of 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nDecember 13, 2021\nPage 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Robert Glassman",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell has already briefed why the attorney-client privilege does not protect Mr. Glassman from having to testify that he told the government that he told Jane it would \"help her case\" if she cooperated with the government and testified against Ms. Maxwell. Dec. 3, 2021 Maxwell Letter re Attorney Glassman. Mr. Glassman's statement to Jane was not intended to be confidential and was not in fact maintained as confidential. Id. But even if the privilege did apply, it was waived when Mr. Glassman communicated the statement to the government. Id.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "There is a second category of relevant and non-privileged testimony Mr. Glassman has to offer. Jane claimed to remember certain events happening in 1994 because that was the year Mr. Epstein took her to see the Broadway production of The Lion King. As the attached email exchange between AUSA and Mr. Edwards shows, the government quickly recognized a problem with Jane's story because The Lion King did not premiere on Broadway until 1997. Ex. 1 (3509- 010). AUSA Rossmiller and Mr. Glassman then exchanged emails in which AUSA Rossmiller tried to massage the problem and not-so-subtly invited Jane to change her story to say that she had actually seen The Lion King movie, not the play. But Jane, through Mr. Glassman, doubled down, saying in response to AUSA Rossmiller's email she saw the Broadway production of The Lion King, not the movie:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Broadway play... Epstein bragged about being good friends with Julie Taymor, and we had amazing first row mezzanine seats they she had apparently given him.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Ex. 1.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "There is nothing privileged about this evidence. At the request of AUSA Rossmiller, Mr. Glassman went back to Jane about her The Lion King story. Knowing that the request came from the government, Jane stuck to her story, and Mr. Glassman communicated that response to the government.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008370",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Robert Glassman",
      "Maxwell",
      "Jane",
      "Epstein",
      "Julie Taymor",
      "Rossmiller",
      "Edwards"
    ],
    "organizations": [
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "December 13, 2021",
      "December 3, 2021",
      "1994",
      "1997"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 544",
      "Ex. 1",
      "DOJ-OGR-00008370"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Maxwell and Epstein. The text discusses the testimony of Robert Glassman and the attorney-client privilege. The document is well-formatted and free of significant damage or redactions."
}