{
  "document_metadata": {
    "page_number": "42 of 69",
    "document_number": "382",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 42 of 69\n\nWith Epstein dead, the media focus shifted immediately to Ms. Maxwell who was vilified as Epstein's principal accomplice. In addition, Epstein's accusers were extremely upset, having been denied the opportunity to see Epstein face the allegations against him in open court. Then-Attorney General William Barr publicly vowed that \"[a]ny co-conspirators should not rest easy. The victims deserve justice, and we will ensure they get it.\"21 Thereafter, in announcing the arrest of Ghislaine Maxwell at a choreographed press conference on July 2, 2020, Acting United States Attorney Audrey Strauss boldly announced: \"This case against Ghislaine Maxwell is the prequel to the earlier case we brought against Jeffrey Epstein.\" See https://youtu.be/hGAsZthBKCE.\n\nThe defense is entitled to elicit this evidence, as well as evidence of the public outcry and media scrutiny that followed the Miami Herald articles and Epstein's death, to argue that the government initially focused the New York investigation on Epstein and charged only him in the initial July 2, 2019 indictment in order to rectify the perceived injustice that the NPA was a \"sweetheart deal\" for Epstein. When Epstein died, however, the government had to scramble to quickly build a case against his purported co-conspirators, including Ms. Maxwell. The defense is further entitled to argue that the public pressure to charge Epstein's co-conspirators and the attendant focus on Ms. Maxwell caused the government to engage in a hasty and sloppy investigation in which they ignored inconsistencies in the evidence, accepted the witness' statements at face value without testing them or verifying them with corroborating evidence, and generally exhibited a \"remarkably uncritical attitude\" to the evidence against Ms. Maxwell.\n\nKyles at 445, 448 (police's acceptance of main witness' statements, which were \"replete with\n\n21 8/12/2019 Remarks of Attorney General William Barr to the Fraternal Order of Police (New Orleans, LA, Aug. 12, 2019) available at https://www.justice.gov/opa/speech/attorney-general-william-p-barr-delivers-remarks-grand-lodge-fraternal-order-polices-64th.\n\n34\nDOJ-OGR-00005497",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 42 of 69",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "With Epstein dead, the media focus shifted immediately to Ms. Maxwell who was vilified as Epstein's principal accomplice. In addition, Epstein's accusers were extremely upset, having been denied the opportunity to see Epstein face the allegations against him in open court. Then-Attorney General William Barr publicly vowed that \"[a]ny co-conspirators should not rest easy. The victims deserve justice, and we will ensure they get it.\"21 Thereafter, in announcing the arrest of Ghislaine Maxwell at a choreographed press conference on July 2, 2020, Acting United States Attorney Audrey Strauss boldly announced: \"This case against Ghislaine Maxwell is the prequel to the earlier case we brought against Jeffrey Epstein.\" See https://youtu.be/hGAsZthBKCE.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The defense is entitled to elicit this evidence, as well as evidence of the public outcry and media scrutiny that followed the Miami Herald articles and Epstein's death, to argue that the government initially focused the New York investigation on Epstein and charged only him in the initial July 2, 2019 indictment in order to rectify the perceived injustice that the NPA was a \"sweetheart deal\" for Epstein. When Epstein died, however, the government had to scramble to quickly build a case against his purported co-conspirators, including Ms. Maxwell. The defense is further entitled to argue that the public pressure to charge Epstein's co-conspirators and the attendant focus on Ms. Maxwell caused the government to engage in a hasty and sloppy investigation in which they ignored inconsistencies in the evidence, accepted the witness' statements at face value without testing them or verifying them with corroborating evidence, and generally exhibited a \"remarkably uncritical attitude\" to the evidence against Ms. Maxwell.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Kyles at 445, 448 (police's acceptance of main witness' statements, which were \"replete with",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "21 8/12/2019 Remarks of Attorney General William Barr to the Fraternal Order of Police (New Orleans, LA, Aug. 12, 2019) available at https://www.justice.gov/opa/speech/attorney-general-william-p-barr-delivers-remarks-grand-lodge-fraternal-order-polices-64th.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "34",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005497",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell",
      "Jeffrey Epstein",
      "William Barr",
      "Audrey Strauss"
    ],
    "organizations": [
      "Fraternal Order of Police",
      "Miami Herald",
      "United States Attorney"
    ],
    "locations": [
      "New York",
      "New Orleans",
      "LA"
    ],
    "dates": [
      "July 2, 2020",
      "July 2, 2019",
      "August 12, 2019",
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "382",
      "DOJ-OGR-00005497"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ghislaine Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 42 of 69."
}