{
  "document_metadata": {
    "page_number": "18 of 34",
    "document_number": "285",
    "date": "05/20/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 285 Filed 05/20/21 Page 18 of 34\n\nTwo of the sources in the Daily News article insisted there was a second meeting in the summer of 2016.12\n\nIn addition, as described above, AUSA in 2021 said she recalls contemplating a perjury prosecution of Maxwell. Ex. K, p 5. But if there were only the one meeting, it makes little sense for AUSA to have been thinking about a potential perjury prosecution in February of 2016, before Maxwell had even been deposed (unless the plan was to set a perjury trap for Maxwell). It is more likely that AUSA contemplated a perjury prosecution after a second meeting with Giuffre's attorneys, which took place after at least one of Maxwell's depositions. As reported in the Daily News, \"David [Boies] was particularly frustrated by the failure to pursue a perjury charge.\"13 \"We have her dead to rights,\" he said.14\n\nThis Court cannot accept without further inquiry the government's assertion that there wasn't a second meeting or any further contact between the U.S. Attorney's Office and Giuffre's attorneys. At a minimum, an evidentiary hearing is required.\n\n• Defense 5: AUSA had no idea what was in Boies Schiller's files.\n\nThe government stands by the claim that AUSA had \"either little or no additional information than [Judge McMahon did] in terms of what materials there are [and] who was deposed\" and, for all the government knew, the deposition transcripts would show \"page after page of people taking the Fifth.\" See Resp. at 70. The government's Response is not credible.\n\n12 Supra Note 10.\n13 Supra Note 10.\n14 Supra Note 10.\n\n13\nDOJ-OGR-00004153",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 285 Filed 05/20/21 Page 18 of 34",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Two of the sources in the Daily News article insisted there was a second meeting in the summer of 2016.12\n\nIn addition, as described above, AUSA in 2021 said she recalls contemplating a perjury prosecution of Maxwell. Ex. K, p 5. But if there were only the one meeting, it makes little sense for AUSA to have been thinking about a potential perjury prosecution in February of 2016, before Maxwell had even been deposed (unless the plan was to set a perjury trap for Maxwell). It is more likely that AUSA contemplated a perjury prosecution after a second meeting with Giuffre's attorneys, which took place after at least one of Maxwell's depositions. As reported in the Daily News, \"David [Boies] was particularly frustrated by the failure to pursue a perjury charge.\"13 \"We have her dead to rights,\" he said.14\n\nThis Court cannot accept without further inquiry the government's assertion that there wasn't a second meeting or any further contact between the U.S. Attorney's Office and Giuffre's attorneys. At a minimum, an evidentiary hearing is required.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "• Defense 5: AUSA had no idea what was in Boies Schiller's files.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "The government stands by the claim that AUSA had \"either little or no additional information than [Judge McMahon did] in terms of what materials there are [and] who was deposed\" and, for all the government knew, the deposition transcripts would show \"page after page of people taking the Fifth.\" See Resp. at 70. The government's Response is not credible.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "12 Supra Note 10.\n13 Supra Note 10.\n14 Supra Note 10.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "13",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004153",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Giuffre",
      "David Boies",
      "Judge McMahon"
    ],
    "organizations": [
      "Daily News",
      "Boies Schiller",
      "U.S. Attorney's Office"
    ],
    "locations": [],
    "dates": [
      "2016",
      "2021",
      "05/20/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 285",
      "Ex. K, p 5",
      "Resp. at 70",
      "DOJ-OGR-00004153"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions, likely related to a high-profile case involving Maxwell and Giuffre. The text discusses the government's assertion regarding a second meeting and the credibility of the government's response."
}