{
  "document_metadata": {
    "page_number": "15 of 34",
    "document_number": "285",
    "date": "05/20/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 285 Filed 05/20/21 Page 15 of 34\n\nFrom any perspective, therefore, AUSA 2021 version of events is not worthy of credence, nor is the government's Response to Maxwell's Motion, which adopts AUSA version of events (to the extent she claims to remember them) while ignoring the contemporaneous evidence of what actually happened. The record is surpassingly clear: In February 2016 and the weeks and months after, Giuffre's attorneys \"pitched\" a prosecution of Maxwell and Epstein.9\n\n- Defense 2: The government was not asked to consider a perjury charge against Maxwell.\n\nNoting that the February 29, 2016 meeting occurred before Maxwell's two depositions (April and July 2016), the government insists that Giuffre's attorneys did not ask (indeed could not have asked) the government to consider charging Maxwell with perjury. Resp. at 63. Again, the documentary evidence belies this claim.\n\nFirst, AUSA contemporaneous notes say that \"Giuffre wants prosecution.\" Ex. J, p 7. AUSA knew what Giuffre's attorneys were after, which is why she emailed the Chief of the Criminal Division just days after the meeting to discuss the \"intriguing\" case, Ex. M.\n\nSecond, in the 2021 interview with prosecutors, AUSA did not deny that Giuffre's attorneys asked her to consider a perjury prosecution. Ex. K, p 5. Instead, AUSA said that she \"does not remember one way or the other if any of the attorneys referenced the possibility of perjury.\" Id.\n\n9 There are other indications as well that Giuffre's attorneys pressed AUSA to investigate Maxwell. For example, while AUSA notes say \"is wanting to cooperate,\" Ex. J, p 2, they say nothing of the sort about Maxwell, instead describing her as Epstein's \"head recruiter,\" id. See also Ex. O.\n\n10\nDOJ-OGR-00004150",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 285 Filed 05/20/21 Page 15 of 34",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "From any perspective, therefore, AUSA 2021 version of events is not worthy of credence, nor is the government's Response to Maxwell's Motion, which adopts AUSA version of events (to the extent she claims to remember them) while ignoring the contemporaneous evidence of what actually happened. The record is surpassingly clear: In February 2016 and the weeks and months after, Giuffre's attorneys \"pitched\" a prosecution of Maxwell and Epstein.9",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "- Defense 2: The government was not asked to consider a perjury charge against Maxwell.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Noting that the February 29, 2016 meeting occurred before Maxwell's two depositions (April and July 2016), the government insists that Giuffre's attorneys did not ask (indeed could not have asked) the government to consider charging Maxwell with perjury. Resp. at 63. Again, the documentary evidence belies this claim.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "First, AUSA contemporaneous notes say that \"Giuffre wants prosecution.\" Ex. J, p 7. AUSA knew what Giuffre's attorneys were after, which is why she emailed the Chief of the Criminal Division just days after the meeting to discuss the \"intriguing\" case, Ex. M.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Second, in the 2021 interview with prosecutors, AUSA did not deny that Giuffre's attorneys asked her to consider a perjury prosecution. Ex. K, p 5. Instead, AUSA said that she \"does not remember one way or the other if any of the attorneys referenced the possibility of perjury.\" Id.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "9 There are other indications as well that Giuffre's attorneys pressed AUSA to investigate Maxwell. For example, while AUSA notes say \"is wanting to cooperate,\" Ex. J, p 2, they say nothing of the sort about Maxwell, instead describing her as Epstein's \"head recruiter,\" id. See also Ex. O.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "10",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004150",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Epstein",
      "Giuffre",
      "AUSA"
    ],
    "organizations": [
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "February 2016",
      "April 2016",
      "July 2016",
      "05/20/21",
      "February 29, 2016"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 285",
      "DOJ-OGR-00004150"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions, likely related to a high-profile case involving Maxwell and Epstein. The text is mostly printed, with some footnotes and references to exhibits."
}