{
  "document_metadata": {
    "page_number": "49",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "the defendant asks this Court to authorize an extensive and burdensome fishing expedition, premised on the defendant's pure conjecture. The Court should deny the motion.\n\nAlthough the defendant asserts that the Court is obligated to conduct a hearing, she has failed to establish that any hearing is warranted. The defendant argues that courts conduct evidentiary hearings \"where the existence or scope of a plea agreement or non-prosecution agreement is in genuine dispute.\" (Def. Mot. 1 at 29). But the defendant has not established any genuine factual dispute in this case that a hearing would be required to resolve. The defendant has offered bare conclusions in support of her motion, which are refuted by governing law, record evidence, and the four corners of the agreement itself. That is not a basis for a hearing.\n\nAs the Second Circuit explained in United States v. Aleman, 286 F.3d 86 (2d Cir. 2002), \"a district court need not conduct a hearing every time a defendant summarily accuses the government of failing to live up to an alleged bargain.\" Id. at 91. In that case, the court held that a hearing was required because the defendant had submitted affidavits from his attorney, as well as corroborating affidavits from other attorneys, and the Government had not submitted any evidence. Id.; see also United States v. Sattar, 272 F. Supp. 2d 348, 383 (S.D.N.Y. 2003) (applying Aleman, and ordering an evidentiary hearing based upon the defendant's submission of an affidavit from an attorney with knowledge of the alleged oral agreement). Similarly, in United States v. Feldman, 939 F.3d 182 (2d Cir. 2019), the Second Circuit held that a hearing was required based on the defendant's uncontested assertions about specific representations made to him by a prosecutor. Id. at 184, 190. Here, by contrast, the defendant has offered no evidence in support of her allegations.\n\nThe defendant cannot seriously argue that she has made the type of showing that requires a hearing. For example, she has not offered any affidavits from Epstein's former defense attorneys",
  "text_blocks": [
    {
      "type": "printed",
      "content": "the defendant asks this Court to authorize an extensive and burdensome fishing expedition, premised on the defendant's pure conjecture. The Court should deny the motion.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Although the defendant asserts that the Court is obligated to conduct a hearing, she has failed to establish that any hearing is warranted. The defendant argues that courts conduct evidentiary hearings \"where the existence or scope of a plea agreement or non-prosecution agreement is in genuine dispute.\" (Def. Mot. 1 at 29). But the defendant has not established any genuine factual dispute in this case that a hearing would be required to resolve. The defendant has offered bare conclusions in support of her motion, which are refuted by governing law, record evidence, and the four corners of the agreement itself. That is not a basis for a hearing.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As the Second Circuit explained in United States v. Aleman, 286 F.3d 86 (2d Cir. 2002), \"a district court need not conduct a hearing every time a defendant summarily accuses the government of failing to live up to an alleged bargain.\" Id. at 91. In that case, the court held that a hearing was required because the defendant had submitted affidavits from his attorney, as well as corroborating affidavits from other attorneys, and the Government had not submitted any evidence. Id.; see also United States v. Sattar, 272 F. Supp. 2d 348, 383 (S.D.N.Y. 2003) (applying Aleman, and ordering an evidentiary hearing based upon the defendant's submission of an affidavit from an attorney with knowledge of the alleged oral agreement). Similarly, in United States v. Feldman, 939 F.3d 182 (2d Cir. 2019), the Second Circuit held that a hearing was required based on the defendant's uncontested assertions about specific representations made to him by a prosecutor. Id. at 184, 190. Here, by contrast, the defendant has offered no evidence in support of her allegations.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant cannot seriously argue that she has made the type of showing that requires a hearing. For example, she has not offered any affidavits from Epstein's former defense attorneys",
      "position": "bottom"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Second Circuit",
      "Court"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "04/16/21",
      "2002",
      "2003",
      "2019"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "Case 1:20-cr-00330-PAE",
      "286 F.3d 86",
      "272 F. Supp. 2d 348",
      "939 F.3d 182",
      "DOJ-OGR-00002983"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is likely a page from a larger filing, as indicated by the page number (49 of 239) at the top."
}