{
  "document_metadata": {
    "page_number": "75 of 84",
    "document_number": "397",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 75 of 84 maintained a contact book containing what purports to be this list of names and associated contact information. Second, the defendant moves to preclude any items seized during the 2005 search of Epstein's home in Palm Beach, Florida. The defense claims, in a conclusory fashion, that \"no witness has sufficient personal knowledge about the proposed exhibits\" to demonstrate authenticity, because \"the evidence collection and retention in this matter is an unreliable mess.\" (Def. Mot. 8 at 3-5). The defense further speculates that the Government intends to offer these exhibits without any testimony about their authenticity, in part because the original custodian—Detective Recarey—is dead. (Id. at 4-5). The defense is mistaken. The Government intends to call live witnesses to establish the authenticity of the evidence at trial.18 Third, the defendant argues that Government Exhibit 251 and 288 are irrelevant. (Def. Mot. 13 at 2). 18 As to Government Exhibit 295 specifically, that exhibit was written by both Detective Recarey and another witness who is expected to testify at trial. The exhibit is primarily marked for identification, although portions of that document may be offered as a past recollection recorded by that other witness. See Fed. R. Evid. 803(5). The Government will not offer statements from Detective Recarey. 74 DOJ-OGR-00005858",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 75 of 84",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "maintained a contact book containing what purports to be this list of names and associated contact information. Second, the defendant moves to preclude any items seized during the 2005 search of Epstein's home in Palm Beach, Florida. The defense claims, in a conclusory fashion, that \"no witness has sufficient personal knowledge about the proposed exhibits\" to demonstrate authenticity, because \"the evidence collection and retention in this matter is an unreliable mess.\" (Def. Mot. 8 at 3-5). The defense further speculates that the Government intends to offer these exhibits without any testimony about their authenticity, in part because the original custodian—Detective Recarey—is dead. (Id. at 4-5). The defense is mistaken. The Government intends to call live witnesses to establish the authenticity of the evidence at trial.18 Third, the defendant argues that Government Exhibit 251 and 288 are irrelevant. (Def. Mot. 13 at 2).",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "18 As to Government Exhibit 295 specifically, that exhibit was written by both Detective Recarey and another witness who is expected to testify at trial. The exhibit is primarily marked for identification, although portions of that document may be offered as a past recollection recorded by that other witness. See Fed. R. Evid. 803(5). The Government will not offer statements from Detective Recarey.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "74",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005858",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Detective Recarey",
      "Epstein"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [
      "Palm Beach",
      "Florida"
    ],
    "dates": [
      "10/29/21",
      "2005"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 397",
      "Government Exhibit 251",
      "Government Exhibit 288",
      "Government Exhibit 295",
      "DOJ-OGR-00005858"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with some footnotes and a header/footer. There are no visible stamps or handwritten text."
}