{
  "document_metadata": {
    "page_number": "8",
    "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 8 of 13\nThe Honorable Alison J. Nathan\nDecember 16, 2021\nPage 8\nin the group massages. To the contrary, in a September 2019 interview, Jane told the government that Emmy and Michelle \"were involved in the sexual contact.\" See 3509-001, p 4. Jane made this claim about Michelle when discussing the abuse she claims to have suffered in New York when she was \"young.\" Id.\nMichelle's testimony will contradict Jane's testimony because she will deny being involved in the sexualized massages that Jane claims she was a part of.\nContrary to the government's argument, there is no doubt Michelle Healy, who Ms. Maxwell intends to call as a witness, is the same \"Michelle\" who Jane claimed both during her testimony and her September 2019 interview was involved in group sexualized massages with Mr. Epstein. Jane told the government in September 2019 that Michelle was \"short\" and that she introduced Jane to \"white Russians,\" a vodka cocktail. See 3509-001, p 4. Michelle Healy is short, and Michelle will testify that she drinks white Russians. And, as Jane testified on the stand, Michelle will testify that she was good friends with Emmy Taylor, a point the government ignores in its letter.\nAs with Eva, Ms. Maxwell has a right to present the testimony of Michelle, who will deny Jane's allegations of being involved the group sexualized massages that are the basis of the charges in this case.4\n4 Michelle has other relevant testimony to offer, in addition to contradicting Jane's account of the group sexualized massages. The government does not challenge this other testimony.\nDOJ-OGR-00011370",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 723 Filed 07/12/22 Page 8 of 13",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nDecember 16, 2021\nPage 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "in the group massages. To the contrary, in a September 2019 interview, Jane told the government that Emmy and Michelle \"were involved in the sexual contact.\" See 3509-001, p 4. Jane made this claim about Michelle when discussing the abuse she claims to have suffered in New York when she was \"young.\" Id.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "Michelle's testimony will contradict Jane's testimony because she will deny being involved in the sexualized massages that Jane claims she was a part of.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "Contrary to the government's argument, there is no doubt Michelle Healy, who Ms. Maxwell intends to call as a witness, is the same \"Michelle\" who Jane claimed both during her testimony and her September 2019 interview was involved in group sexualized massages with Mr. Epstein. Jane told the government in September 2019 that Michelle was \"short\" and that she introduced Jane to \"white Russians,\" a vodka cocktail. See 3509-001, p 4. Michelle Healy is short, and Michelle will testify that she drinks white Russians. And, as Jane testified on the stand, Michelle will testify that she was good friends with Emmy Taylor, a point the government ignores in its letter.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "As with Eva, Ms. Maxwell has a right to present the testimony of Michelle, who will deny Jane's allegations of being involved the group sexualized massages that are the basis of the charges in this case.4",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "4 Michelle has other relevant testimony to offer, in addition to contradicting Jane's account of the group sexualized massages. The government does not challenge this other testimony.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011370",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Jane",
      "Emmy",
      "Michelle",
      "Michelle Healy",
      "Eva",
      "Emmy Taylor",
      "Mr. Epstein",
      "Ms. Maxwell"
    ],
    "organizations": [],
    "locations": [
      "New York"
    ],
    "dates": [
      "September 2019",
      "December 16, 2021",
      "07/12/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 723",
      "3509-001",
      "DOJ-OGR-00011370"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ghislaine Maxwell, discussing the testimony of various witnesses and their potential contradictions."
}