{
  "document_metadata": {
    "page_number": "8",
    "document_number": "389",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 389 Filed 10/29/21 Page 8 of 11\noffenses is significantly outweighed by the risk of unfair prejudice, juror confusion, and undue delay and should be excluded. See Fed. R. Evid. 403.\nSeparate and apart from the Court's prior ruling, the government has not established a sufficient connection between the alleged false statements and the alleged sex abuse offenses to introduce the statements as evidence of concealment of the latter. The alleged false statements were made at unrelated civil depositions in 2016, over 20 years after the conduct underlying the Mann Act offenses supposedly took place, at a time when Ms. Maxwell was not under investigation. Indeed, Ms. Maxwell was never a subject of the Palm Beach FBI investigation that concluded in 2008 and was not named as a co-conspirator in Epstein's Non-Prosecution Agreement that resolved that investigation. Hence, there is no sound basis to assert that Ms. Maxwell made false statements to conceal her involvement in Epstein's crimes.\nFurthermore, the superseding indictment does not allege that Ms. Maxwell's purported false statements were the result of an agreement with Epstein to conceal their alleged conduct or were otherwise part of, or an object of, the conspiracies charged in the non-perjury counts.\nInstead, the superseding indictment alleges that the purported false statements were part of a separate and independent effort by Ms. Maxwell to conceal her alleged involvement in Epstein's sex abuse offenses long after those offenses had already been completed. Accordingly, the statements are not sufficiently connected to the non-perjury counts to allow this evidence to be introduced as proof of concealment of those offenses. See United States v. Marcus Schloss & Co., Inc., 710 F. Supp. 944, 946-50 (S.D.N.Y. 1989) (precluding evidence of defendants' alleged attempts to obstruct SEC investigation as proof of the underlying insider trading conspiracy when conspiracy was already over and there was no evidence of an \"express original agreement\"\n5\nDOJ-OGR-00005709",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 389 Filed 10/29/21 Page 8 of 11",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "offenses is significantly outweighed by the risk of unfair prejudice, juror confusion, and undue delay and should be excluded. See Fed. R. Evid. 403.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Separate and apart from the Court's prior ruling, the government has not established a sufficient connection between the alleged false statements and the alleged sex abuse offenses to introduce the statements as evidence of concealment of the latter. The alleged false statements were made at unrelated civil depositions in 2016, over 20 years after the conduct underlying the Mann Act offenses supposedly took place, at a time when Ms. Maxwell was not under investigation. Indeed, Ms. Maxwell was never a subject of the Palm Beach FBI investigation that concluded in 2008 and was not named as a co-conspirator in Epstein's Non-Prosecution Agreement that resolved that investigation. Hence, there is no sound basis to assert that Ms. Maxwell made false statements to conceal her involvement in Epstein's crimes.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Furthermore, the superseding indictment does not allege that Ms. Maxwell's purported false statements were the result of an agreement with Epstein to conceal their alleged conduct or were otherwise part of, or an object of, the conspiracies charged in the non-perjury counts.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Instead, the superseding indictment alleges that the purported false statements were part of a separate and independent effort by Ms. Maxwell to conceal her alleged involvement in Epstein's sex abuse offenses long after those offenses had already been completed. Accordingly, the statements are not sufficiently connected to the non-perjury counts to allow this evidence to be introduced as proof of concealment of those offenses. See United States v. Marcus Schloss & Co., Inc., 710 F. Supp. 944, 946-50 (S.D.N.Y. 1989) (precluding evidence of defendants' alleged attempts to obstruct SEC investigation as proof of the underlying insider trading conspiracy when conspiracy was already over and there was no evidence of an \"express original agreement\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005709",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Epstein",
      "Marcus Schloss"
    ],
    "organizations": [
      "FBI",
      "SEC"
    ],
    "locations": [
      "Palm Beach",
      "S.D.N.Y."
    ],
    "dates": [
      "2016",
      "2008",
      "10/29/21",
      "1989"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 389",
      "DOJ-OGR-00005709"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, discussing the admissibility of certain evidence. The text is printed and there are no visible stamps or handwritten notes."
}