{
  "document_metadata": {
    "page_number": "6",
    "document_number": "208-1",
    "date": "04/16/2024",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Jeffrey Epstein, and (2) the Government violated their CVRA rights by concealing the non-prosecution agreement with them. (DE 280 at 3; see id. at 7-8). However, the bulk of the Rule 21 Motion consists of copious factual details that Jane Doe 3 and Jane Doe 4 \"would prove\" \"[i]f allowed to join this action.\" (Id. at 3, 7). Specifically, Jane Doe 3 proffers that she could prove the circumstances under which a non-party introduced her to Mr. Epstein, and how Mr. Epstein sexually trafficked her to several high-profile non-party individuals, \"including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.\" (Id. at 3-6). She names several individuals, and she offers details about the type of sex acts performed and where they took place. (See id. at 5).2 At this juncture in the proceedings, these lurid details are unnecessary to the determination of whether Jane Doe 3 and Jane Doe 4 should be permitted to join Petitioners' claim that the Government violated their rights under the CVRA. The factual details regarding with whom and where the Jane Does engaged in sexual activities are immaterial and impertinent to this central claim (i.e., that they were known victims of Mr. Epstein and the Government owed them CVRA duties), especially considering that these details involve non-parties who are not related to the respondent Government. These unnecessary details shall be stricken. The original Rule 21 Motion (DE 279) shall be stricken in its entirety, as it is wholly superseded by the \"corrected\" version of the Rule 21 Motion (DE 280). From the corrected Rule 21 Motion, the Court shall strike all factual details regarding Jane Doe 3 between the following sentences: \"The Government then concealed from Jane Doe #3 the existence of its NPA from 2 Jane Doe 4's proffer is limited to sexual acts between Mr. Epstein and herself. (See DE 280 at 7-8). 5 GIUFFRE002848 DOJ-OGR-00003730",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Jeffrey Epstein, and (2) the Government violated their CVRA rights by concealing the non-prosecution agreement with them. (DE 280 at 3; see id. at 7-8). However, the bulk of the Rule 21 Motion consists of copious factual details that Jane Doe 3 and Jane Doe 4 \"would prove\" \"[i]f allowed to join this action.\" (Id. at 3, 7). Specifically, Jane Doe 3 proffers that she could prove the circumstances under which a non-party introduced her to Mr. Epstein, and how Mr. Epstein sexually trafficked her to several high-profile non-party individuals, \"including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders.\" (Id. at 3-6). She names several individuals, and she offers details about the type of sex acts performed and where they took place. (See id. at 5).2 At this juncture in the proceedings, these lurid details are unnecessary to the determination of whether Jane Doe 3 and Jane Doe 4 should be permitted to join Petitioners' claim that the Government violated their rights under the CVRA. The factual details regarding with whom and where the Jane Does engaged in sexual activities are immaterial and impertinent to this central claim (i.e., that they were known victims of Mr. Epstein and the Government owed them CVRA duties), especially considering that these details involve non-parties who are not related to the respondent Government. These unnecessary details shall be stricken. The original Rule 21 Motion (DE 279) shall be stricken in its entirety, as it is wholly superseded by the \"corrected\" version of the Rule 21 Motion (DE 280). From the corrected Rule 21 Motion, the Court shall strike all factual details regarding Jane Doe 3 between the following sentences: \"The Government then concealed from Jane Doe #3 the existence of its NPA from",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "2 Jane Doe 4's proffer is limited to sexual acts between Mr. Epstein and herself. (See DE 280 at 7-8).",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "page number"
    },
    {
      "type": "printed",
      "content": "GIUFFRE002848 DOJ-OGR-00003730",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Jane Doe 3",
      "Jane Doe 4",
      "Jane Doe #3",
      "Mr. Epstein"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "04/16/2024"
    ],
    "reference_numbers": [
      "DE 280",
      "DE 279",
      "DE 208-1",
      "GIUFFRE002848",
      "DOJ-OGR-00003730"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the Jeffrey Epstein case, discussing the CVRA rights of Jane Doe 3 and Jane Doe 4. The text is mostly printed, with a footnote and page number. There are no visible stamps or handwritten text."
}