{
  "document_metadata": {
    "page_number": "15",
    "document_number": "224",
    "date": "04/20/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 224 Filed 04/20/21 Page 15 of 17 one or more of Ms. Maxwell's lawyers should become actual witnesses, a circumstance that would create a circus, not a fair trial. The truth of the matter is simple: the government included the Perjury Counts because it wants to call Ms. Maxwell a liar in front of the jury and because it wanted a way to introduce unrelated, but extremely prejudicial evidence of alleged sexual abuse through the back door. The simple, non-prejudicial, solution is to sever the Perjury Counts.7 CONCLUSION The Perjury Counts are improperly joined with the Mann Act Counts. A joint trial of these charges would deny Ms. Maxwell her right to a fair trial and her counsel. Accordingly, the Court should grant the request for a separate trial on the Perjury Counts. Dated: March 15, 2021 Respectfully submitted, s/ Jeffrey S. Pagliuca 7 Ms. Maxwell's Colorado Counsel would not participate as advocates in any trial of those charges but would testify as witnesses. 11 DOJ-OGR-00003912",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 224 Filed 04/20/21 Page 15 of 17",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "one or more of Ms. Maxwell's lawyers should become actual witnesses, a circumstance that would create a circus, not a fair trial. The truth of the matter is simple: the government included the Perjury Counts because it wants to call Ms. Maxwell a liar in front of the jury and because it wanted a way to introduce unrelated, but extremely prejudicial evidence of alleged sexual abuse through the back door. The simple, non-prejudicial, solution is to sever the Perjury Counts.7",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "CONCLUSION",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Perjury Counts are improperly joined with the Mann Act Counts. A joint trial of these charges would deny Ms. Maxwell her right to a fair trial and her counsel. Accordingly, the Court should grant the request for a separate trial on the Perjury Counts.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dated: March 15, 2021 Respectfully submitted, s/ Jeffrey S. Pagliuca",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "7 Ms. Maxwell's Colorado Counsel would not participate as advocates in any trial of those charges but would testify as witnesses.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "11 DOJ-OGR-00003912",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Jeffrey S. Pagliuca"
    ],
    "organizations": [],
    "locations": [
      "Colorado"
    ],
    "dates": [
      "March 15, 2021",
      "04/20/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 224",
      "DOJ-OGR-00003912"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is well-formatted and printed, with no visible handwriting or stamps. The document includes a signature block with the name 'Jeffrey S. Pagliuca'."
}