{
  "document_metadata": {
    "page_number": "213",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 213 of 239\nin ____________________. Accordingly, the records of these interviews constitute witness statements covered by the Jencks Act and are not subject to disclosure by statute until after each witness has completed direct examination at trial. See 18 U.S.C. § 3500. As noted above, however, the Government fully intends to provide all Jencks Act material of both testifying and non-testifying witnesses, which will of course include the records relating to these interviews, to the defense multiple weeks in advance of trial. The Government respectfully submits that is sufficient to meet its obligations with respect to these documents, and the defendant's motion for their immediate disclosure should be denied.\nSecond, the defendant's request for an unredacted copy of the FBI report attached to the Defense Motion as Exhibit C should be denied as moot because the Government has already produced an unredacted copy of that report to the defense. (Def. Mot. 10 at 8-9). Specifically, the document was produced without redactions under bates numbers SDNY_GM_00380550 through SDNY_GM_00380554 as part of the Government's discovery production dated November 9, 2020.66 This motion should accordingly be denied as moot.\nThird, the defendant's request for unredacted copies of the FBI report regarding ____________________ is based purely on her speculation that the redacted portions of those materials contain exculpatory information. (Def. Mot. 10 at 8-9). Once again, the ____________________. Out of an abundance of caution, today the Government has informed defense counsel of this single line ____________________.\n66 Notably, the unredacted report does not contain ____________________ demonstrating that defense counsel's speculation about supposed Brady material lurking beneath redactions is inaccurate. The redacted copy defense counsel attached as Exhibit C was recovered during the execution of a search warrant for one of Epstein's devices and was produced to defense counsel in the form in which it was recovered from the device. In other words, defense counsel has received two copies of this same document: the redacted version that Epstein had on one of his devices, and the unredacted version from the FBI's files.\n186\nDOJ-OGR-00003147",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 213 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "in ____________________. Accordingly, the records of these interviews constitute witness statements covered by the Jencks Act and are not subject to disclosure by statute until after each witness has completed direct examination at trial. See 18 U.S.C. § 3500. As noted above, however, the Government fully intends to provide all Jencks Act material of both testifying and non-testifying witnesses, which will of course include the records relating to these interviews, to the defense multiple weeks in advance of trial. The Government respectfully submits that is sufficient to meet its obligations with respect to these documents, and the defendant's motion for their immediate disclosure should be denied.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Second, the defendant's request for an unredacted copy of the FBI report attached to the Defense Motion as Exhibit C should be denied as moot because the Government has already produced an unredacted copy of that report to the defense. (Def. Mot. 10 at 8-9). Specifically, the document was produced without redactions under bates numbers SDNY_GM_00380550 through SDNY_GM_00380554 as part of the Government's discovery production dated November 9, 2020.66 This motion should accordingly be denied as moot.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Third, the defendant's request for unredacted copies of the FBI report regarding ____________________ is based purely on her speculation that the redacted portions of those materials contain exculpatory information. (Def. Mot. 10 at 8-9). Once again, the ____________________. Out of an abundance of caution, today the Government has informed defense counsel of this single line ____________________.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "66 Notably, the unredacted report does not contain ____________________ demonstrating that defense counsel's speculation about supposed Brady material lurking beneath redactions is inaccurate. The redacted copy defense counsel attached as Exhibit C was recovered during the execution of a search warrant for one of Epstein's devices and was produced to defense counsel in the form in which it was recovered from the device. In other words, defense counsel has received two copies of this same document: the redacted version that Epstein had on one of his devices, and the unredacted version from the FBI's files.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "186",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003147",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein"
    ],
    "organizations": [
      "FBI",
      "SDNY",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "04/16/21",
      "November 9, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "SDNY_GM_00380550",
      "SDNY_GM_00380554",
      "DOJ-OGR-00003147"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions. The text is mostly printed, with some blank spaces indicating redactions."
}