{
  "document_metadata": {
    "page_number": "11",
    "document_number": "723",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 723 Filed 07/12/22 Page 11 of 13\nThe Honorable Alison J. Nathan December 16, 2021 Page 11 contradiction, prior inconsistent statement, bias and mental capacity) to Rules 402 and 403.\").5 Cf. United States v. Schuler, 458 F.3d 1148, 1155 (10th Cir. 2006) (“[A] matter is collateral if it could not have been introduced in evidence for any purpose other than impeachment.”).\nE. The government’s other arguments fail.\nThe government offers three other arguments. First, the government faults Ms. Maxwell for not showing Jane pictures of Eva, Michelle, and Kelly. Nothing required Ms. Maxwell to do that, and the government cites no authority for its argument.\nWhat’s more telling is that the government never showed Jane their photographs. The government’s deliberate choice to muddy the waters is not Ms. Maxwell’s fault or her problem.\nThe record shows Eva Dubin, Michelle Healy, and Kelly Bovino are the “Eva,” “Michelle,” and “Kelly” who Jane testified about. Their testimony is admissible.\nSecond, it’s irrelevant that Ms. Maxwell did not use last names in her examination of Jane. For one thing, Jane also did not use last names in her interviews with the FBI. For another thing, Eva Dubin’s name was already on the record from Mr. Visoski’s testimony, and Jane admitted knowing Kelly’s last name. Finally, Ms. Maxwell did not use Michelle’s last name in part because she intended to ask this Court for anonymity. It’s immaterial that this Court subsequently denied that request.\nFinally, the government mistakenly relies on cases purporting to hold that a defendant, through cross-examination, cannot open the door to proving collateral issues by extrinsic\n5 The government quite rightly does not make a 403 argument. And its relevance argument—that the testimony of Eva, Michelle, and Kelly does not contradict Jane’s testimony—is wrong, as described above.\nDOJ-OGR-00011373",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 723 Filed 07/12/22 Page 11 of 13",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan December 16, 2021 Page 11",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "contradiction, prior inconsistent statement, bias and mental capacity) to Rules 402 and 403.\").5 Cf. United States v. Schuler, 458 F.3d 1148, 1155 (10th Cir. 2006) (“[A] matter is collateral if it could not have been introduced in evidence for any purpose other than impeachment.”).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "E. The government’s other arguments fail.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The government offers three other arguments. First, the government faults Ms. Maxwell for not showing Jane pictures of Eva, Michelle, and Kelly. Nothing required Ms. Maxwell to do that, and the government cites no authority for its argument.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "What’s more telling is that the government never showed Jane their photographs. The government’s deliberate choice to muddy the waters is not Ms. Maxwell’s fault or her problem.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The record shows Eva Dubin, Michelle Healy, and Kelly Bovino are the “Eva,” “Michelle,” and “Kelly” who Jane testified about. Their testimony is admissible.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Second, it’s irrelevant that Ms. Maxwell did not use last names in her examination of Jane. For one thing, Jane also did not use last names in her interviews with the FBI. For another thing, Eva Dubin’s name was already on the record from Mr. Visoski’s testimony, and Jane admitted knowing Kelly’s last name. Finally, Ms. Maxwell did not use Michelle’s last name in part because she intended to ask this Court for anonymity. It’s immaterial that this Court subsequently denied that request.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Finally, the government mistakenly relies on cases purporting to hold that a defendant, through cross-examination, cannot open the door to proving collateral issues by extrinsic",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "5 The government quite rightly does not make a 403 argument. And its relevance argument—that the testimony of Eva, Michelle, and Kelly does not contradict Jane’s testimony—is wrong, as described above.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011373",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Eva Dubin",
      "Michelle Healy",
      "Kelly Bovino",
      "Jane",
      "Ms. Maxwell",
      "Mr. Visoski"
    ],
    "organizations": [
      "FBI"
    ],
    "locations": [],
    "dates": [
      "December 16, 2021",
      "07/12/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 723",
      "DOJ-OGR-00011373"
    ]
  },
  "additional_notes": "The document appears to be a court filing, likely a legal brief or memorandum, discussing the admissibility of certain testimony and evidence in a criminal case. The text is printed and there are no visible stamps or handwritten annotations."
}