{
  "document_metadata": {
    "page_number": "8",
    "document_number": "717",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 717 Filed 07/12/22 Page 8 of 10\nThe Honorable Alison J. Nathan\nDecember 12, 2021\nPage 8\ndeniers Jane's claims, if Jane is telling the truth, then Michelle is a victim just as much as Jane is.\nSee 18 U.S.C. 3771(e)(2)(A) (the Crime Victims Act, defining “crime victim” means as “a person directly and proximately harmed as a result of the commission of a Federal offense”).\nThus, for the very same reasons Carolyn could testify using only her first name, so too should Michelle be permitted to testify using her first name only. See TR 11/1/2021, pp 6-13. (It would be impractical for Michelle to use a pseudonym since her true first name is already in the record, though her last name is not.) If Michelle Healy's full name is revealed to the public, she will be subject to the same scorn, harassment, embarrassment, and intimidation that this Court relied on to grant witnesses like Carolyn the privilege of testifying using only their first names. TR 11/1/2021, p 6:20-23 (“[L]imiting disclosure here would protect the alleged victims from potential harassment from the media and others, undue embarrassment and other adverse consequences.”); see Gov. Mot. in Limine, pp 3-14 (citing authority and arguing for anonymity for the alleged victims in this case).\nC.\nis an adult,. There is no allegation that she is the victim of any improper or illegal conduct by Mr. Epstein or Ms. Maxwell. Even so, Ms.desires to testify using a pseudonym given the media hysteria surrounding this case and the inevitable harassment and intimidation that will follow because of being outed as a “masseuse” associated with Mr. Epstein.\nNot only will Ms.be subject to harassment and intimidation if her true name is disclosed, disclosure will also threaten the “loss of employment potentially resulting from trial publicity.” See Marcus, 2007 WL 330388, at *1. Because Ms. Healy's true name is not relevant,\nDOJ-OGR-00011327",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 717 Filed 07/12/22 Page 8 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nDecember 12, 2021\nPage 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "deniers Jane's claims, if Jane is telling the truth, then Michelle is a victim just as much as Jane is.\nSee 18 U.S.C. 3771(e)(2)(A) (the Crime Victims Act, defining “crime victim” means as “a person directly and proximately harmed as a result of the commission of a Federal offense”).\nThus, for the very same reasons Carolyn could testify using only her first name, so too should Michelle be permitted to testify using her first name only. See TR 11/1/2021, pp 6-13. (It would be impractical for Michelle to use a pseudonym since her true first name is already in the record, though her last name is not.) If Michelle Healy's full name is revealed to the public, she will be subject to the same scorn, harassment, embarrassment, and intimidation that this Court relied on to grant witnesses like Carolyn the privilege of testifying using only their first names. TR 11/1/2021, p 6:20-23 (“[L]imiting disclosure here would protect the alleged victims from potential harassment from the media and others, undue embarrassment and other adverse consequences.”); see Gov. Mot. in Limine, pp 3-14 (citing authority and arguing for anonymity for the alleged victims in this case).",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "C.\nis an adult,. There is no allegation that she is the victim of any improper or illegal conduct by Mr. Epstein or Ms. Maxwell. Even so, Ms.desires to testify using a pseudonym given the media hysteria surrounding this case and the inevitable harassment and intimidation that will follow because of being outed as a “masseuse” associated with Mr. Epstein.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Not only will Ms.be subject to harassment and intimidation if her true name is disclosed, disclosure will also threaten the “loss of employment potentially resulting from trial publicity.” See Marcus, 2007 WL 330388, at *1. Because Ms. Healy's true name is not relevant,",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011327",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Jane",
      "Michelle",
      "Carolyn",
      "Michelle Healy",
      "Mr. Epstein",
      "Ms. Maxwell",
      "Ms.",
      "Marcus"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "December 12, 2021",
      "07/12/22",
      "11/1/2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 717",
      "18 U.S.C. 3771(e)(2)(A)",
      "TR 11/1/2021",
      "Gov. Mot. in Limine",
      "Marcus, 2007 WL 330388",
      "DOJ-OGR-00011327"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Mr. Epstein and Ms. Maxwell. The text discusses the potential harassment and intimidation that witnesses may face if their identities are revealed. The document includes redactions for certain individuals' names."
}