{
  "document_metadata": {
    "page_number": "2",
    "document_number": "358",
    "date": "October 18, 2021",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 358 Filed 10/18/21 Page 2 of 4\nThe Honorable Alison J. Nathan\nOctober 18, 2021\nPage 2\nto Exclude Government Exhibit 52, an Unauthenticated Hearsay Document from\nSuspect Sources;\nto Exclude Items Purportedly Seized During Search of 358 El Brillo Way on October 20, 2005;\nto Suppress Identification;\nto Preclude Law Enforcement Witnesses from Offering Expert Opinion Testimony;\nto Preclude Testimony About Any Alleged \"Rape\" by Jeffrey Epstein;\nto Preclude Reference to the Accusers as \"Victims\" or \"Minor Victims\"; and\nto Preclude Introduction of Government's Exhibits 251, 288, 294, 313 and 606.\n\nTemporary Sealing\nSome of the memoranda and exhibits in support of the motions in limine contain Confidential Information produced in discovery that is governed by paragraph 15 of the Protective Order (Dkt. 36). Accordingly, pursuant to our prior practice, we will not file the memoranda and exhibits on the public docket until we are instructed to do so by the Court. Instead, we will submit the memoranda and exhibits by email to the Court and the government under seal—pursuant to Rule 2(B) of the Court's individual rules of criminal practice—to give both parties the opportunity to propose and justify any redactions it deems necessary. The government has agreed to do the same for its motions in limine. We will, however, file the Notice of Motion and this cover letter on the public docket because they do not contain Confidential Information.\n\nReservation of Rights to File Additional Motions in Limine\nAs directed by the Court, we endeavored to comply with today's filing deadline, but as previously raised with the government and the Court, additional time is required to determine\nDOJ-OGR-00005261",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 358 Filed 10/18/21 Page 2 of 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nOctober 18, 2021\nPage 2",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "to Exclude Government Exhibit 52, an Unauthenticated Hearsay Document from\nSuspect Sources;\nto Exclude Items Purportedly Seized During Search of 358 El Brillo Way on October 20, 2005;\nto Suppress Identification;\nto Preclude Law Enforcement Witnesses from Offering Expert Opinion Testimony;\nto Preclude Testimony About Any Alleged \"Rape\" by Jeffrey Epstein;\nto Preclude Reference to the Accusers as \"Victims\" or \"Minor Victims\"; and\nto Preclude Introduction of Government's Exhibits 251, 288, 294, 313 and 606.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Temporary Sealing\nSome of the memoranda and exhibits in support of the motions in limine contain Confidential Information produced in discovery that is governed by paragraph 15 of the Protective Order (Dkt. 36). Accordingly, pursuant to our prior practice, we will not file the memoranda and exhibits on the public docket until we are instructed to do so by the Court. Instead, we will submit the memoranda and exhibits by email to the Court and the government under seal—pursuant to Rule 2(B) of the Court's individual rules of criminal practice—to give both parties the opportunity to propose and justify any redactions it deems necessary. The government has agreed to do the same for its motions in limine. We will, however, file the Notice of Motion and this cover letter on the public docket because they do not contain Confidential Information.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Reservation of Rights to File Additional Motions in Limine\nAs directed by the Court, we endeavored to comply with today's filing deadline, but as previously raised with the government and the Court, additional time is required to determine",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005261",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Jeffrey Epstein"
    ],
    "organizations": [],
    "locations": [
      "El Brillo Way"
    ],
    "dates": [
      "October 18, 2021",
      "October 20, 2005"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 358",
      "Dkt. 36",
      "DOJ-OGR-00005261",
      "251",
      "288",
      "294",
      "313",
      "606",
      "52"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving Jeffrey Epstein. The text is mostly printed, with no visible handwriting or stamps. The document contains references to various court exhibits and a protective order."
}