{
  "document_metadata": {
    "page_number": "7",
    "document_number": "456",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 456 Filed 11/12/21 Page 7 of 10\nPage 7\nthat is specifically charged in the indictment\" or that is the subject of the relevant trial. Gigante, 166 F.3d at 82; see also Maldonado-Rivera, 922 F.2d at 962 (\"Though . . . Fed. R. Evid. 801(d)(2)(E) requires proof that both the declarant and the party against whom a declaration is offered be members of the same conspiracy, it does not require that the conspiracy be one charged in the indictment.\"). Employee-1's testimony regarding the continuing conspiracy thus satisfies Rule 801(d)(2)(E)'s first prong.\nWhen making this statement, Epstein was attempting to induce Employee-1's cooperation to effect the conspiracy's goals. See, e.g., United States v. Gupta, 747 F.3d 111, 125 (2d Cir. 2014) (\"Statements designed to induce the listener's assistance with respect to the conspiracy's goals satisfy the Rule's in-furtherance requirement.\"). Here, Epstein's statement to Employee-1 was intended to convey to Employee-1 that other employees had participated in the conspiracy to traffic minors and to encourage Employee-1 to similarly participate. See United States v. Beech-Nut Nutrition Corp., 871 F.2d 1181, 1199 (2d Cir. 1989) (\"Coconspirator statements may be found to be 'in furtherance' of the conspiracy within the meaning of Rule 801(d)(2)(E) if they 'prompt the listener to respond in a way that facilitates the carrying out of criminal activity.'\" (quoting Rahme, 813 F.2d at 35)). Epstein's statement reassured Employee-1 that Employee-1 would not be alone among his employees by participating in his scheme and informed Employee-1 about the history of the conspiracy. Further, Epstein's statement conveyed to Employee-1 that the defendant was someone who had participated in the scheme and accordingly could be trusted. See Simmons, 923 F.2d at 945 (statements between co-conspirators that \"provide reassurance, serve to maintain trust and cohesiveness among them, or inform each other of the current status of the conspiracy,\" further the conspiracy); see also United States v. Handy, 668 F.2d 407, 408 (8th Cir. 1982) (statement of\nDOJ-OGR-00006959",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 456 Filed 11/12/21 Page 7 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "that is specifically charged in the indictment\" or that is the subject of the relevant trial. Gigante, 166 F.3d at 82; see also Maldonado-Rivera, 922 F.2d at 962 (\"Though . . . Fed. R. Evid. 801(d)(2)(E) requires proof that both the declarant and the party against whom a declaration is offered be members of the same conspiracy, it does not require that the conspiracy be one charged in the indictment.\"). Employee-1's testimony regarding the continuing conspiracy thus satisfies Rule 801(d)(2)(E)'s first prong.\nWhen making this statement, Epstein was attempting to induce Employee-1's cooperation to effect the conspiracy's goals. See, e.g., United States v. Gupta, 747 F.3d 111, 125 (2d Cir. 2014) (\"Statements designed to induce the listener's assistance with respect to the conspiracy's goals satisfy the Rule's in-furtherance requirement.\"). Here, Epstein's statement to Employee-1 was intended to convey to Employee-1 that other employees had participated in the conspiracy to traffic minors and to encourage Employee-1 to similarly participate. See United States v. Beech-Nut Nutrition Corp., 871 F.2d 1181, 1199 (2d Cir. 1989) (\"Coconspirator statements may be found to be 'in furtherance' of the conspiracy within the meaning of Rule 801(d)(2)(E) if they 'prompt the listener to respond in a way that facilitates the carrying out of criminal activity.'\" (quoting Rahme, 813 F.2d at 35)). Epstein's statement reassured Employee-1 that Employee-1 would not be alone among his employees by participating in his scheme and informed Employee-1 about the history of the conspiracy. Further, Epstein's statement conveyed to Employee-1 that the defendant was someone who had participated in the scheme and accordingly could be trusted. See Simmons, 923 F.2d at 945 (statements between co-conspirators that \"provide reassurance, serve to maintain trust and cohesiveness among them, or inform each other of the current status of the conspiracy,\" further the conspiracy); see also United States v. Handy, 668 F.2d 407, 408 (8th Cir. 1982) (statement of",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006959",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Gigante",
      "Maldonado-Rivera",
      "Gupta",
      "Rahme",
      "Simmons",
      "Handy",
      "Employee-1"
    ],
    "organizations": [
      "Beech-Nut Nutrition Corp."
    ],
    "locations": [],
    "dates": [
      "11/12/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 456",
      "DOJ-OGR-00006959"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving Epstein. The text discusses the admissibility of certain statements under Rule 801(d)(2)(E) of the Federal Rules of Evidence. The document is well-formatted and free of significant damage or redactions."
}