{
  "document_metadata": {
    "page_number": "3",
    "document_number": "334",
    "date": "08/13/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page 3 of 10\n\nRecipient-1's original journal for inspection and copying; (3) a pair of black boots that Maxwell and Jeffrey Epstein allegedly gave to Subpoena Recipient-1; (4) production of the original copies of certain photographs of Subpoena Recipient-1; and (5) materials related to the Epstein Victim Compensation Fund. As the Court previously noted, all of these requests fail the Nixon test.\n\nThe request for any contingent or engagement agreements fails because Maxwell has not made the required showing that such records would be relevant or admissible. The only plausible theory of relevance set forth in Maxwell's papers is that these documents are necessary for purposes of impeachment. See Dkt. No. 252, April 27, 2021 Op., at 4–5. The need to impeach witnesses generally “is insufficient to require [materials'] production in advance of trial.” Nixon, 418 U.S. at 701. As a result, many courts have held that mere impeachment material does not become relevant until after the witness testifies. United States v. Skelos, No. 15-CR-317 (KMW), 2018 WL 2254538, at *2 (S.D.N.Y. May 17, 2018)), aff'd, 988 F.3d 645 (2d Cir. 2021) (collecting cases). Here, there is no other plausible theory of relevance to these materials—and Maxwell does not advance any explanation, other than impeachment, as to why these materials might be relevant under the Nixon test. Lacking any relevance or admissibility, the request is improper for purposes of Rule 17(c). In any event, there is little risk that review of these materials, if they become relevant and admissible, will lead to a delay at trial, given their limited volume. United States v. Seabrook, No. 16-CR-467 (ALC), 2017 WL 4838311, at *2 (S.D.N.Y. Oct. 23, 2017). If the materials become relevant at trial, Maxwell will be able to procure them at that time.\n\nMaxwell's request for production of Subpoena Recipient-1's journal also fails the Nixon test. As the Court noted in its June 2, 2021 opinion, the original and complete journal is not the proper subject of a Rule 17(c) subpoena. As already noted, mere impeachment purposes do not\n\n3\n\nDOJ-OGR-00005032",
  "text_blocks": [
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      "content": "Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page 3 of 10",
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    {
      "type": "printed",
      "content": "Recipient-1's original journal for inspection and copying; (3) a pair of black boots that Maxwell and Jeffrey Epstein allegedly gave to Subpoena Recipient-1; (4) production of the original copies of certain photographs of Subpoena Recipient-1; and (5) materials related to the Epstein Victim Compensation Fund. As the Court previously noted, all of these requests fail the Nixon test.",
      "position": "top"
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    {
      "type": "printed",
      "content": "The request for any contingent or engagement agreements fails because Maxwell has not made the required showing that such records would be relevant or admissible. The only plausible theory of relevance set forth in Maxwell's papers is that these documents are necessary for purposes of impeachment. See Dkt. No. 252, April 27, 2021 Op., at 4–5. The need to impeach witnesses generally “is insufficient to require [materials'] production in advance of trial.” Nixon, 418 U.S. at 701. As a result, many courts have held that mere impeachment material does not become relevant until after the witness testifies. United States v. Skelos, No. 15-CR-317 (KMW), 2018 WL 2254538, at *2 (S.D.N.Y. May 17, 2018)), aff'd, 988 F.3d 645 (2d Cir. 2021) (collecting cases). Here, there is no other plausible theory of relevance to these materials—and Maxwell does not advance any explanation, other than impeachment, as to why these materials might be relevant under the Nixon test. Lacking any relevance or admissibility, the request is improper for purposes of Rule 17(c). In any event, there is little risk that review of these materials, if they become relevant and admissible, will lead to a delay at trial, given their limited volume. United States v. Seabrook, No. 16-CR-467 (ALC), 2017 WL 4838311, at *2 (S.D.N.Y. Oct. 23, 2017). If the materials become relevant at trial, Maxwell will be able to procure them at that time.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Maxwell's request for production of Subpoena Recipient-1's journal also fails the Nixon test. As the Court noted in its June 2, 2021 opinion, the original and complete journal is not the proper subject of a Rule 17(c) subpoena. As already noted, mere impeachment purposes do not",
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    {
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      "content": "3",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005032",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Maxwell",
      "Jeffrey Epstein",
      "Nixon"
    ],
    "organizations": [
      "Court",
      "DOJ"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "08/13/21",
      "April 27, 2021",
      "May 17, 2018",
      "June 2, 2021",
      "Oct. 23, 2017"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 334",
      "Dkt. No. 252",
      "15-CR-317 (KMW)",
      "16-CR-467 (ALC)",
      "DOJ-OGR-00005032"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case United States v. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 3 of 10."
}