{
  "document_metadata": {
    "page_number": "4",
    "document_number": "705",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 705 Filed 07/12/22 Page 4 of 12\nThe Honorable Alison J. Nathan\nMay 12, 2021\nPage 4\nand is belied by an \"understanding\" months earlier where the government represented that Accuser-2 \"stopped writing in her journal about a month after\" her meeting with Epstein, Dkt. 100, p. 11 n.2.\nIncredibly, the government has never examined or taken possession of the journal and is relying on the representations of lawyers adverse to Ms. Maxwell in multiple civil litigations, the same lawyers who have taken an active role in providing the government with selective pieces of evidence and who regularly bash Ms. Maxwell in the media, hardly a reliable source.2\nIt is fundamentally wrong to use a part of a writing to, for example, deny bail, or refresh recollection, or as a past-recollection recorded, or as a prior-consistent statement, and at the same time ignore the remainder of the writing. The government should know what is in the remainder of the journal; it simply chooses selective ignorance and relies on lawyers adverse to Ms. Maxwell for cover. This type of selective disclosure of information is routinely rejected by courts, including the Second Circuit Court of Appeals. Known as the \"fairness doctrine,\" when one party makes assertions about parts of a communication or writing the entire communication loses protected status and requires disclosure to the opposing party. The aim of the doctrine is to protect the adverse \"party, the factfinder, and the judicial process from selectively disclosed and potentially misleading evidence.\" In re von Bulow, 828 F.2d 94, 102 (2d Cir. 1987); see also United States v. Bilzerian, 926 F.2d 1285, 1292 (2d Cir. 1991); Joy v. North, 692 F.2d 880, 893-94 (2d Cir. 1982); Teachers Ins. & Annuity Ass'n of America v. Shamrock Broadcasting Co., 521 F.Supp. 638 (S.D.N.Y. 1981).\n2 As Ms. Maxwell previously pointed out, another of BSF's clients confessed to creating a fake \"diary\" to sell to a tabloid news journalist, fifteen years after the fact, and while represented by BSF. See Dkt. 244 at 10 n.4.\nDOJ-OGR-00011244",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 705 Filed 07/12/22 Page 4 of 12",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nMay 12, 2021\nPage 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "and is belied by an \"understanding\" months earlier where the government represented that Accuser-2 \"stopped writing in her journal about a month after\" her meeting with Epstein, Dkt. 100, p. 11 n.2.\nIncredibly, the government has never examined or taken possession of the journal and is relying on the representations of lawyers adverse to Ms. Maxwell in multiple civil litigations, the same lawyers who have taken an active role in providing the government with selective pieces of evidence and who regularly bash Ms. Maxwell in the media, hardly a reliable source.2\nIt is fundamentally wrong to use a part of a writing to, for example, deny bail, or refresh recollection, or as a past-recollection recorded, or as a prior-consistent statement, and at the same time ignore the remainder of the writing. The government should know what is in the remainder of the journal; it simply chooses selective ignorance and relies on lawyers adverse to Ms. Maxwell for cover. This type of selective disclosure of information is routinely rejected by courts, including the Second Circuit Court of Appeals. Known as the \"fairness doctrine,\" when one party makes assertions about parts of a communication or writing the entire communication loses protected status and requires disclosure to the opposing party. The aim of the doctrine is to protect the adverse \"party, the factfinder, and the judicial process from selectively disclosed and potentially misleading evidence.\" In re von Bulow, 828 F.2d 94, 102 (2d Cir. 1987); see also United States v. Bilzerian, 926 F.2d 1285, 1292 (2d Cir. 1991); Joy v. North, 692 F.2d 880, 893-94 (2d Cir. 1982); Teachers Ins. & Annuity Ass'n of America v. Shamrock Broadcasting Co., 521 F.Supp. 638 (S.D.N.Y. 1981).",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "2 As Ms. Maxwell previously pointed out, another of BSF's clients confessed to creating a fake \"diary\" to sell to a tabloid news journalist, fifteen years after the fact, and while represented by BSF. See Dkt. 244 at 10 n.4.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011244",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Epstein",
      "Ms. Maxwell",
      "Ms. Maxwell",
      "von Bulow",
      "Bilzerian",
      "Joy",
      "North"
    ],
    "organizations": [
      "Second Circuit Court of Appeals",
      "BSF"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "May 12, 2021",
      "07/12/22",
      "1987",
      "1991",
      "1982",
      "1981"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 705",
      "Dkt. 100",
      "Dkt. 244",
      "828 F.2d 94",
      "926 F.2d 1285",
      "692 F.2d 880",
      "521 F.Supp. 638",
      "DOJ-OGR-00011244"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of United States v. Ghislaine Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 4 of a 12-page filing."
}