{
  "document_metadata": {
    "page_number": "11",
    "document_number": "208-2",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 208-2 Filed 04/16/21 Page 11 of 15\nCase 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 10 of 14\n\nJane Doe #3's and Jane Doe #4's participation is also directly relevant to the discovery disputes currently pending in this case. The Government has raised various relevancy objections to the documents that Jane Doe #1 and Jane Doe #2 are attempting to obtain. The current victims have responded by explaining how these documents are relevant, including explaining how these documents might bear on the way in which Epstein used his powerful political and social connections to secure a favorable plea deal, as well as provide proof of the Government's motive to deliberately fail to investigate certain aspects of the victims' claims in an effort to maintain the secrecy of the facts and resolve the case without the victims' knowledge. See, e.g., DE 266 at 6-10. Jane Doe #3 and Jane Doe #4's participation will help prove the relevancy of these requests, as well as the need for those requests.\n\nOne clear example is Request for Production No. 8, which seeks documents regarding Epstein's lobbying efforts to persuade the Government to give him a more favorable plea arrangement and/or non-prosecution agreement, including efforts on his behalf by Prince Andrew and former Harvard Law Professor Alan Dershowitz. Jane Doe #1 and Jane Doe #2 have alleged these materials are needed to prove their allegations that, after Epstein signed the non-prosecution agreement, his performance was delayed while he used his significant social and political connections to lobby the Justice Department to obtain a more favorable plea deal. See, e.g., DE 225 at 7-8 (discussing DE 48 at 16-18). Jane Doe #3 has directly person knowledge of Epstein's connection with some of these powerful people and thus how Epstein might have used them to secure favorable treatment.\n\nAdding two new victims to this case will not delay any of the proceedings. They will simply join in motions that the current victims were going to file in any event. For example, the\n10\nGIUFFRE 004297 CONFIDENTIAL\nDOJ-OGR-00003746",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 208-2 Filed 04/16/21 Page 11 of 15",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 10 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Jane Doe #3's and Jane Doe #4's participation is also directly relevant to the discovery disputes currently pending in this case. The Government has raised various relevancy objections to the documents that Jane Doe #1 and Jane Doe #2 are attempting to obtain. The current victims have responded by explaining how these documents are relevant, including explaining how these documents might bear on the way in which Epstein used his powerful political and social connections to secure a favorable plea deal, as well as provide proof of the Government's motive to deliberately fail to investigate certain aspects of the victims' claims in an effort to maintain the secrecy of the facts and resolve the case without the victims' knowledge. See, e.g., DE 266 at 6-10. Jane Doe #3 and Jane Doe #4's participation will help prove the relevancy of these requests, as well as the need for those requests.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "One clear example is Request for Production No. 8, which seeks documents regarding Epstein's lobbying efforts to persuade the Government to give him a more favorable plea arrangement and/or non-prosecution agreement, including efforts on his behalf by Prince Andrew and former Harvard Law Professor Alan Dershowitz. Jane Doe #1 and Jane Doe #2 have alleged these materials are needed to prove their allegations that, after Epstein signed the non-prosecution agreement, his performance was delayed while he used his significant social and political connections to lobby the Justice Department to obtain a more favorable plea deal. See, e.g., DE 225 at 7-8 (discussing DE 48 at 16-18). Jane Doe #3 has directly person knowledge of Epstein's connection with some of these powerful people and thus how Epstein might have used them to secure favorable treatment.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Adding two new victims to this case will not delay any of the proceedings. They will simply join in motions that the current victims were going to file in any event. For example, the",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "10",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "GIUFFRE 004297 CONFIDENTIAL",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003746",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jane Doe #1",
      "Jane Doe #2",
      "Jane Doe #3",
      "Jane Doe #4",
      "Epstein",
      "Prince Andrew",
      "Alan Dershowitz"
    ],
    "organizations": [
      "Government",
      "Justice Department",
      "Harvard Law"
    ],
    "locations": [],
    "dates": [
      "04/16/21",
      "01/02/2015"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 208-2",
      "Case 9:08-cv-80736-KAM",
      "Document 280",
      "DE 266",
      "DE 225",
      "DE 48",
      "Request for Production No. 8",
      "GIUFFRE 004297",
      "DOJ-OGR-00003746"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the Jeffrey Epstein case, discussing the relevance of certain documents and the participation of additional victims in the case. The document is marked 'CONFIDENTIAL' and contains references to various docket entries and case numbers."
}