{
  "document_metadata": {
    "page_number": "6",
    "document_number": "525",
    "date": "December 5, 2021",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 525 Filed 12/05/21 Page 6 of 9\nThe Honorable Alison J. Nathan\nDecember 5, 2021\nPage 6\nwas accurate. Gov. Letter at 8. But that argument would work only if there were evidence that the 2019 photos look like what photos from 1994 or 1995 or 1996 would have looked like. And as the government does not deny, there's no such evidence.\nThe government does not dispute that it could have asked Jane to authenticate the photos by showing the photographs to her when she testified. Gov. Letter at 8 n.3. According to the government, however, \"[b]efore showing the photographs to Jane on the stand, the Government would surely need to show her the photographs in advance,\" and that would have \"vitiat[ed] the photographs' value as independent corroboration.\" Id. This is a baseless argument.\nThe government easily could have showed the photographs to Jane for the first time during her testimony, asked her if she recognized them, asked whether the photos accurately depicted the house and massage room as it existed in 1994 or 1995 or 1996, or at least asked if the photographs looked similar to what the apartment looked like back then. In turn, once the government elicited testimony from another witness about when the photographs were taken, it could have moved to admit them. This procedure would have addressed the government's concern about preserving the photographs as independent corroboration of Jane's testimony. The only conceivable thing stopping the government from doing this was a concern that Jane would not give the answer the government wanted.\nBut even if this procedure would have \"vitiat[ed] the photographs' value as independent corroboration,\" that's just how trials go. Sometimes tradeoffs are necessary to comply with the rules of evidence. And having to make such a tradeoff does not mean Ms. Maxwell was wrong to object or the Court was wrong to sustain.\nDOJ-OGR-00008230",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 525 Filed 12/05/21 Page 6 of 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nDecember 5, 2021\nPage 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "was accurate. Gov. Letter at 8. But that argument would work only if there were evidence that the 2019 photos look like what photos from 1994 or 1995 or 1996 would have looked like. And as the government does not deny, there's no such evidence.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "The government does not dispute that it could have asked Jane to authenticate the photos by showing the photographs to her when she testified. Gov. Letter at 8 n.3. According to the government, however, \"[b]efore showing the photographs to Jane on the stand, the Government would surely need to show her the photographs in advance,\" and that would have \"vitiat[ed] the photographs' value as independent corroboration.\" Id. This is a baseless argument.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "The government easily could have showed the photographs to Jane for the first time during her testimony, asked her if she recognized them, asked whether the photos accurately depicted the house and massage room as it existed in 1994 or 1995 or 1996, or at least asked if the photographs looked similar to what the apartment looked like back then. In turn, once the government elicited testimony from another witness about when the photographs were taken, it could have moved to admit them. This procedure would have addressed the government's concern about preserving the photographs as independent corroboration of Jane's testimony. The only conceivable thing stopping the government from doing this was a concern that Jane would not give the answer the government wanted.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "But even if this procedure would have \"vitiat[ed] the photographs' value as independent corroboration,\" that's just how trials go. Sometimes tradeoffs are necessary to comply with the rules of evidence. And having to make such a tradeoff does not mean Ms. Maxwell was wrong to object or the Court was wrong to sustain.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008230",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Jane",
      "Ms. Maxwell"
    ],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [],
    "dates": [
      "December 5, 2021",
      "1994",
      "1995",
      "1996",
      "2019"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "525",
      "DOJ-OGR-00008230"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is well-formatted and legible. There are no visible redactions or damage to the document."
}