{
  "document_metadata": {
    "page_number": "74",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 74 of 239\n\n2018 respectively, would have testified, and that such testimony would have been exculpatory and would have materially helped the defense. (Def. Mot. 7 at 9-11). The defendant cannot establish that Casey and Detective Recarey would have testified in a way that would help, rather than hurt, the defendant.\n\nIn particular, the defendant contends that Michael Casey, the purported agent of Minor Victim-1, “would be able to testify” about Minor Victim-1's behavior during the “relevant time period” and the “lack of any ‘outcry’ or ‘grooming.’” (Id. at 10). The defense suggests that Casey not having related any complaints about Maxwell to “any authority, Ms. Maxwell, or any other known witness” means that he knew of no complaints. (Id. at 9-10). As an initial matter, “there is no evidence before the Court as to what [Casey] would have testified.” Scala, 388 F. Supp. 2d at 400. Even assuming that Casey would have testified as the defendant now contends, such testimony (which would be purely speculative and unsubstantiated) would also have no bearing on whether the abuse, in fact, occurred.\n\nThe defendant argues that Detective Recarey would have testified that none of the witnesses with whom he spoke in connection with a prior investigation told him about the defendant participating in sex trafficking activities. (Def. Mot. 7 at 10-11). As a threshold matter, the defendant has not established how such testimony, which would consist entirely of hearsay, could even be admissible at the defendant’s trial. Moreover, the fact that Epstein may have abused victims without the defendant’s participation is not exculpatory as to charges alleging the defendant assisted in the grooming and abuse of other victims. The well-established law of this Circuit generally precludes a defendant from offering evidence that a defendant did not participate in criminal conduct on a particular occasion—or of her law-abiding conduct during uncharged periods or uncharged events—to rebut the Government’s evidence with respect to the charged",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 74 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "2018 respectively, would have testified, and that such testimony would have been exculpatory and would have materially helped the defense. (Def. Mot. 7 at 9-11). The defendant cannot establish that Casey and Detective Recarey would have testified in a way that would help, rather than hurt, the defendant.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In particular, the defendant contends that Michael Casey, the purported agent of Minor Victim-1, “would be able to testify” about Minor Victim-1's behavior during the “relevant time period” and the “lack of any ‘outcry’ or ‘grooming.’” (Id. at 10). The defense suggests that Casey not having related any complaints about Maxwell to “any authority, Ms. Maxwell, or any other known witness” means that he knew of no complaints. (Id. at 9-10). As an initial matter, “there is no evidence before the Court as to what [Casey] would have testified.” Scala, 388 F. Supp. 2d at 400. Even assuming that Casey would have testified as the defendant now contends, such testimony (which would be purely speculative and unsubstantiated) would also have no bearing on whether the abuse, in fact, occurred.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant argues that Detective Recarey would have testified that none of the witnesses with whom he spoke in connection with a prior investigation told him about the defendant participating in sex trafficking activities. (Def. Mot. 7 at 10-11). As a threshold matter, the defendant has not established how such testimony, which would consist entirely of hearsay, could even be admissible at the defendant’s trial. Moreover, the fact that Epstein may have abused victims without the defendant’s participation is not exculpatory as to charges alleging the defendant assisted in the grooming and abuse of other victims. The well-established law of this Circuit generally precludes a defendant from offering evidence that a defendant did not participate in criminal conduct on a particular occasion—or of her law-abiding conduct during uncharged periods or uncharged events—to rebut the Government’s evidence with respect to the charged",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "47",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003008",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Michael Casey",
      "Detective Recarey",
      "Maxwell",
      "Epstein"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "2018",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "Def. Mot. 7",
      "Scala, 388 F. Supp. 2d at 400",
      "DOJ-OGR-00003008"
    ]
  },
  "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 74 of 239."
}