{
  "document_metadata": {
    "page_number": "43",
    "document_number": "657",
    "date": "04/29/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 43 of 45\n\nAnd third, the Defendant does not demonstrate that such witnesses, even if available to testify as the Defendant speculates they may have, would have meaningfully altered her defense such that she was substantially prejudiced by their absence. Pierre-Louis, 2018 WL 4043140, at *4. No witness listed could testify directly to whether or not the Defendant and Epstein sexually abused the victims. Rather, each would at best provide additional corroboration of the Defendant's arguments at trial to impeach the witnesses' credibility as to particular aspects of their testimony. This falls short of substantial prejudice. United States v. Lawson, 683 F.2d 688, 694 (2d Cir. 1982) (no prejudice where absent witness's testimony was \"at best corroborative on minor points\").\n\nSpecifically, the housekeeper's anticipated testimony that the Defendant rarely spent the night at Epstein's townhouse and that she and Epstein were not \"always\" together contradicts little, if any, of the Government's case at trial. Maxwell Br. at 30. The Defendant does not claim that the housekeeper was always aware of the Defendant's or Epstein's actions, and so is unlikely to have rebutted testimony that at other times and other locations, the Defendant and Epstein committed crimes. See Pierre-Louis, 2018 WL 4043140, at *4 (absence of a witness not prejudicial because unless the witness was with the defendant \"every moment,\" it would have been \"impossible for him to testify that defendant did not commit the charged crimes\").\n\nThe speculated testimony of Sally Markham—that an individual known only as \"the Countess,\" not the Defendant, wrote the household manual—is similarly unhelpful to the Defendant's claim. In considering whether testimony would have been beneficial to the Defendant, the Court must consider whether the witness would have been credible and withstood cross-examination. See Maxwell, 534 F. Supp. 3d at 317 (citing United States v. Spears, 159 F.3d 1081, 1085 (7th Cir. 1999)). The Defendant provides no basis to conclude that the jury\n\n43\n\nDOJ-OGR-00010409",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 43 of 45",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "And third, the Defendant does not demonstrate that such witnesses, even if available to testify as the Defendant speculates they may have, would have meaningfully altered her defense such that she was substantially prejudiced by their absence. Pierre-Louis, 2018 WL 4043140, at *4. No witness listed could testify directly to whether or not the Defendant and Epstein sexually abused the victims. Rather, each would at best provide additional corroboration of the Defendant's arguments at trial to impeach the witnesses' credibility as to particular aspects of their testimony. This falls short of substantial prejudice. United States v. Lawson, 683 F.2d 688, 694 (2d Cir. 1982) (no prejudice where absent witness's testimony was \"at best corroborative on minor points\").",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "Specifically, the housekeeper's anticipated testimony that the Defendant rarely spent the night at Epstein's townhouse and that she and Epstein were not \"always\" together contradicts little, if any, of the Government's case at trial. Maxwell Br. at 30. The Defendant does not claim that the housekeeper was always aware of the Defendant's or Epstein's actions, and so is unlikely to have rebutted testimony that at other times and other locations, the Defendant and Epstein committed crimes. See Pierre-Louis, 2018 WL 4043140, at *4 (absence of a witness not prejudicial because unless the witness was with the defendant \"every moment,\" it would have been \"impossible for him to testify that defendant did not commit the charged crimes\").",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "The speculated testimony of Sally Markham—that an individual known only as \"the Countess,\" not the Defendant, wrote the household manual—is similarly unhelpful to the Defendant's claim. In considering whether testimony would have been beneficial to the Defendant, the Court must consider whether the witness would have been credible and withstood cross-examination. See Maxwell, 534 F. Supp. 3d at 317 (citing United States v. Spears, 159 F.3d 1081, 1085 (7th Cir. 1999)). The Defendant provides no basis to conclude that the jury",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "43",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010409",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Defendant",
      "Epstein",
      "Pierre-Louis",
      "Lawson",
      "Maxwell",
      "Sally Markham",
      "Spears"
    ],
    "organizations": [
      "Government",
      "Court",
      "jury"
    ],
    "locations": [
      "Epstein's townhouse"
    ],
    "dates": [
      "04/29/22",
      "2018"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 657",
      "2018 WL 4043140",
      "683 F.2d 688",
      "534 F. Supp. 3d",
      "159 F.3d 1081",
      "DOJ-OGR-00010409"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 43 of 45."
}