{
  "document_metadata": {
    "page_number": "83",
    "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 83 of 239\n\nsatisfied that he should prosecute and will be able promptly to establish guilt beyond a reasonable doubt.\" (internal quotation marks and citations omitted)).\n\nMoreover, even if the Court were to determine that a twenty-six-year period of delay were applicable here, the defendant's motion should be dismissed because she failed to show that the Government acted improperly to obtain a tactical advantage. See, e.g., Pierre-Louis, 2018 WL 4043140 (denying motion to dismiss for pre-indictment delay as to conduct charged in 2016 involving sexual abuse of minors from 1998 to 2007 as defendant failed to satisfy both prongs of pre-indictment delay standard); United States v. Burke, No. 09 Cr. 135 (SJ), 2011 WL 2609837, at *7 (E.D.N.Y. July 1, 2011) (denying motion to dismiss indictment based on thirty-year pre-indictment delay because even if unavailability of alibi witnesses were prejudicial, defendant failed to show that government delayed for its own benefit); United States v. Carbonaro, No. 02 Cr. 743 (RCC), 2004 WL 2222145 (S.D.N.Y. Sept. 30, 2004) (in a racketeering conspiracy case in which a 14-year-old murder was alleged as a predicate act, finding that, even assuming defendant had shown actual prejudice, defendant's motion to dismiss based on pre-indictment delay failed because defendant supplied no evidence that government's conduct was for an improper purpose).\n\nThe defendant claims that the Government intentionally delayed the indictment in this case with a prescient view towards capitalizing on civil litigation. For instance, Maxwell asserts that it \"has been advantageous to the government to have aggressive lawyers collecting information from Ms. Maxwell as part of civil discovery and disseminating that information to the public, as part of an ongoing campaign to vilify Ms. Maxwell.\" (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP (\"Boies Schiller\") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government obtained such materials through a judicially approved and entirely appropriate\n\n56\n\nDOJ-OGR-00003017",
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      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 83 of 239",
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    {
      "type": "printed",
      "content": "satisfied that he should prosecute and will be able promptly to establish guilt beyond a reasonable doubt.\" (internal quotation marks and citations omitted)).\n\nMoreover, even if the Court were to determine that a twenty-six-year period of delay were applicable here, the defendant's motion should be dismissed because she failed to show that the Government acted improperly to obtain a tactical advantage. See, e.g., Pierre-Louis, 2018 WL 4043140 (denying motion to dismiss for pre-indictment delay as to conduct charged in 2016 involving sexual abuse of minors from 1998 to 2007 as defendant failed to satisfy both prongs of pre-indictment delay standard); United States v. Burke, No. 09 Cr. 135 (SJ), 2011 WL 2609837, at *7 (E.D.N.Y. July 1, 2011) (denying motion to dismiss indictment based on thirty-year pre-indictment delay because even if unavailability of alibi witnesses were prejudicial, defendant failed to show that government delayed for its own benefit); United States v. Carbonaro, No. 02 Cr. 743 (RCC), 2004 WL 2222145 (S.D.N.Y. Sept. 30, 2004) (in a racketeering conspiracy case in which a 14-year-old murder was alleged as a predicate act, finding that, even assuming defendant had shown actual prejudice, defendant's motion to dismiss based on pre-indictment delay failed because defendant supplied no evidence that government's conduct was for an improper purpose).",
      "position": "top"
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    {
      "type": "printed",
      "content": "The defendant claims that the Government intentionally delayed the indictment in this case with a prescient view towards capitalizing on civil litigation. For instance, Maxwell asserts that it \"has been advantageous to the government to have aggressive lawyers collecting information from Ms. Maxwell as part of civil discovery and disseminating that information to the public, as part of an ongoing campaign to vilify Ms. Maxwell.\" (Def. Mot. 7 at 16). She again cites the subpoena the Government issued to Boies Schiller & Flexner LLP (\"Boies Schiller\") to obtain materials from the Giuffre civil litigation. (Id.). Leaving aside the fact that, as set forth in Section IV, the Government obtained such materials through a judicially approved and entirely appropriate",
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    {
      "type": "printed",
      "content": "56",
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      "type": "printed",
      "content": "DOJ-OGR-00003017",
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  ],
  "entities": {
    "people": [
      "Maxwell",
      "Giuffre"
    ],
    "organizations": [
      "Boies Schiller & Flexner LLP"
    ],
    "locations": [
      "E.D.N.Y.",
      "S.D.N.Y."
    ],
    "dates": [
      "04/16/21",
      "1998",
      "2007",
      "July 1, 2011",
      "Sept. 30, 2004"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "204",
      "09 Cr. 135",
      "02 Cr. 743"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}