{
  "document_metadata": {
    "page_number": "32 of 54",
    "document_number": "380",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 380 Filed 10/29/21 Page 32 of 54\n\nCir. 2017) (summary order) (instructing jury that the “government is not on trial” is “appropriate” (internal quotation marks omitted)). Introducing evidence about investigative decisions would only confuse the issues properly before the jury and suggest that jurors should focus on the history of investigations into Epstein and his co-conspirators rather than the evidence against the defendant.\n\nJudge Stein’s decision in United States v. Duncan, No. 18 Cr. 289 (SHS) (S.D.N.Y.), is instructive. In that case, a defendant sought to call a case agent on three topics: (1) the length of the FBI’s investigation, (2) the law enforcement techniques that were used and not used, and (3) contacts and communications with that defendant prior to his arrest. Letter, id., Dkt. No. 130. The Court explained that defense counsel “wanted to bring out that [the defendant] was not a target of the investigation for a long period of time.” May 16, 2019 Tr. at 1168:12-23, id., Dkt. No. 159. Citing Saldarriaga, the Court explained that the argument was “absolutely irrelevant,” because “[w]hat matters is whether the government has proven its case against [the defendant] here beyond a reasonable doubt.” Id. at 1168:12-25; see Duncan, 2019 WL 2210663, at *3 (“Evidence about the length of the investigation, the techniques used, and when Locust became a target is therefore not admissible pursuant to Fed. R. Evid. 401.”).\n\nSo too here. It is irrelevant what investigative steps were taken during the Florida investigations or this investigation, and it is irrelevant how long those investigations lasted. Testimony and argument on those points would not assist the jury in evaluating the defendant’s guilt or innocence, but it would confuse the jury by directing them to focus on investigators’ conduct. Especially where the investigative context is complicated and a topic of public interest\n\n31\n\nDOJ-OGR-00005425",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 380 Filed 10/29/21 Page 32 of 54",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Cir. 2017) (summary order) (instructing jury that the “government is not on trial” is “appropriate” (internal quotation marks omitted)). Introducing evidence about investigative decisions would only confuse the issues properly before the jury and suggest that jurors should focus on the history of investigations into Epstein and his co-conspirators rather than the evidence against the defendant.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Judge Stein’s decision in United States v. Duncan, No. 18 Cr. 289 (SHS) (S.D.N.Y.), is instructive. In that case, a defendant sought to call a case agent on three topics: (1) the length of the FBI’s investigation, (2) the law enforcement techniques that were used and not used, and (3) contacts and communications with that defendant prior to his arrest. Letter, id., Dkt. No. 130. The Court explained that defense counsel “wanted to bring out that [the defendant] was not a target of the investigation for a long period of time.” May 16, 2019 Tr. at 1168:12-23, id., Dkt. No. 159. Citing Saldarriaga, the Court explained that the argument was “absolutely irrelevant,” because “[w]hat matters is whether the government has proven its case against [the defendant] here beyond a reasonable doubt.” Id. at 1168:12-25; see Duncan, 2019 WL 2210663, at *3 (“Evidence about the length of the investigation, the techniques used, and when Locust became a target is therefore not admissible pursuant to Fed. R. Evid. 401.”).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "So too here. It is irrelevant what investigative steps were taken during the Florida investigations or this investigation, and it is irrelevant how long those investigations lasted. Testimony and argument on those points would not assist the jury in evaluating the defendant’s guilt or innocence, but it would confuse the jury by directing them to focus on investigators’ conduct. Especially where the investigative context is complicated and a topic of public interest",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "31",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005425",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Judge Stein",
      "Duncan",
      "Saldarriaga"
    ],
    "organizations": [
      "FBI"
    ],
    "locations": [
      "Florida",
      "S.D.N.Y."
    ],
    "dates": [
      "2017",
      "May 16, 2019",
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 380",
      "18 Cr. 289 (SHS)",
      "Dkt. No. 130",
      "Dkt. No. 159",
      "2019 WL 2210663",
      "DOJ-OGR-00005425"
    ]
  },
  "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 page 32 of 54."
}