{
  "document_metadata": {
    "page_number": "30",
    "document_number": "20-cr-330 (AJN) Document 192-2 Filed 08/24/20 Page 36 of 95",
    "date": null,
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "E. The Discovery Contains No Meaningful Documentary Corroboration of the Government's Allegations Against Ms. Maxwell\nAt the initial bail hearing, the government represented to the Court that \"the evidence in this case is strong\" and that the allegations of the alleged victims were \"backed up [by] contemporaneous documents . . . [including] flight records, diary entries, business records, and other evidence.\" (Dkt. 4 at 5.) The Court credited those representations and accepted the government's proffer that the witness testimony would be \"corroborated by significant contemporaneous documentary evidence.\" (Tr. 82) (emphasis added). The defense, of course, could not rebut the government's representations at the hearing because the government had not yet produced discovery.\nSince then, the government has produced, and the defense has reviewed, hundreds of thousands of pages of discovery, including the entire initial tranche of discovery that the government represented was the core of its case against Ms. Maxwell.9 The discovery contains no meaningful documentary corroboration of the allegations whatsoever, much less \"significant\" corroboration that the Court was led to believe existed. The vast majority of the discovery that the defense has reviewed relates to the time period in the 2000s and the 2010s, well after the conspiracy charged in the indictment (1994-1997). These documents include [redacted]. In fact, only [redacted].\nDaily Mail, \"French prosecutors probing Jeffrey Epstein over rape and abuse of children in Paris widen probe to include Ghislaine Maxwell to see if British socialite was involved in his offending,\" (Oct. 25, 2020), https://www.dailymail.co.uk/news/article-8878825/French-prosecutors-probing-Jeffrey-Epstein-widen-probe-include-Ghislaine-Maxwell.html.\n9 The defense has not yet completed its review of the over 1.2 million documents produced on November 9, 2020 and November 18, 2020. This production includes documents and images seized from electronic devices found at Epstein's residences in searches of his residences in 2019. Our initial review, however, shows that the documents are from the 2000s and 2010s, well after the charged conspiracy.\n30\nDOJ-OGR-00001132",
  "text_blocks": [
    {
      "type": "printed",
      "content": "E. The Discovery Contains No Meaningful Documentary Corroboration of the Government's Allegations Against Ms. Maxwell",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "At the initial bail hearing, the government represented to the Court that \"the evidence in this case is strong\" and that the allegations of the alleged victims were \"backed up [by] contemporaneous documents . . . [including] flight records, diary entries, business records, and other evidence.\" (Dkt. 4 at 5.) The Court credited those representations and accepted the government's proffer that the witness testimony would be \"corroborated by significant contemporaneous documentary evidence.\" (Tr. 82) (emphasis added). The defense, of course, could not rebut the government's representations at the hearing because the government had not yet produced discovery.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Since then, the government has produced, and the defense has reviewed, hundreds of thousands of pages of discovery, including the entire initial tranche of discovery that the government represented was the core of its case against Ms. Maxwell.9 The discovery contains no meaningful documentary corroboration of the allegations whatsoever, much less \"significant\" corroboration that the Court was led to believe existed. The vast majority of the discovery that the defense has reviewed relates to the time period in the 2000s and the 2010s, well after the conspiracy charged in the indictment (1994-1997). These documents include [redacted]. In fact, only [redacted].",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Daily Mail, \"French prosecutors probing Jeffrey Epstein over rape and abuse of children in Paris widen probe to include Ghislaine Maxwell to see if British socialite was involved in his offending,\" (Oct. 25, 2020), https://www.dailymail.co.uk/news/article-8878825/French-prosecutors-probing-Jeffrey-Epstein-widen-probe-include-Ghislaine-Maxwell.html.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "9 The defense has not yet completed its review of the over 1.2 million documents produced on November 9, 2020 and November 18, 2020. This production includes documents and images seized from electronic devices found at Epstein's residences in searches of his residences in 2019. Our initial review, however, shows that the documents are from the 2000s and 2010s, well after the charged conspiracy.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "30",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001132",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Ghislaine Maxwell",
      "Jeffrey Epstein"
    ],
    "organizations": [
      "Daily Mail",
      "Court"
    ],
    "locations": [
      "Paris"
    ],
    "dates": [
      "October 25, 2020",
      "November 9, 2020",
      "November 18, 2020",
      "1994-1997",
      "2000s",
      "2010s"
    ],
    "reference_numbers": [
      "20-cr-330 (AJN) Document 192-2",
      "Dkt. 4",
      "Tr. 82",
      "DOJ-OGR-00001132"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ghislaine Maxwell. The text is mostly printed, with some redacted sections. The document includes a reference to a news article from the Daily Mail and a footnote with additional information."
}