{
  "document_metadata": {
    "page_number": "7",
    "document_number": "269",
    "date": "05/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 269 Filed 05/04/21 Page 7 of 9\n\nPage 7\nindividual \"is a prospective witness in this case; the Government will provide Carton with his 3500, Jencks and Giglio material by the deadline set by the Court\"); United States v. Yudong Zhu, No. 13 Cr. 761 (VM), 2014 WL 5366107, at *3 & n.3 (S.D.N.Y. Oct. 14, 2014) (rejecting a subpoena request under Rule 17(h) even though the records were not in the Government's possession). Here, the Government has discharged its obligations already by providing the defendant with the relevant pages from the diary, and Rule 17(h) bars a search for additional statements.\n\nThe defendant's theories miss the mark because Request 9, at its core, is precisely the sort of \"fishing expedition\" that Nixon prohibits. 418 U.S. at 700. Accordingly, Request 9 should be denied.\n\nB. Request 10\n\nThe Government understands Request 10 to seek a pair of boots purchased by the defendant and Jeffrey Epstein for Minor Victim-2. The defendant states that she would like to examine the boots in order to \"identify the make and provenance of the boots.\" (4/2/21 Letter from Def., Dkt. No. 244 at 11). This appears to be an attempt to use the boots to impeach Minor Victim-2's testimony, shrouded again in a conclusory claim about the need for authentication. For substantially the reasons set forth above with respect to the diary, the Government respectfully submits such a claim is meritless under Nixon.\n\nHowever, and although the Government is not obligated to do so, the Government has requested that BSF provide the boots to the Federal Bureau of Investigation (\"FBI\"). BSF has indicated that Minor Victim-2 will likely agree to do so. When the boots are in the FBI's custody, the Government intends to make them available promptly to the defense for examination and use at trial, and will so notify the Court, which should moot Request 10. The Government submits,\n\nDOJ-OGR-00004100",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 269 Filed 05/04/21 Page 7 of 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "individual \"is a prospective witness in this case; the Government will provide Carton with his 3500, Jencks and Giglio material by the deadline set by the Court\"); United States v. Yudong Zhu, No. 13 Cr. 761 (VM), 2014 WL 5366107, at *3 & n.3 (S.D.N.Y. Oct. 14, 2014) (rejecting a subpoena request under Rule 17(h) even though the records were not in the Government's possession). Here, the Government has discharged its obligations already by providing the defendant with the relevant pages from the diary, and Rule 17(h) bars a search for additional statements.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The defendant's theories miss the mark because Request 9, at its core, is precisely the sort of \"fishing expedition\" that Nixon prohibits. 418 U.S. at 700. Accordingly, Request 9 should be denied.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "B. Request 10",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The Government understands Request 10 to seek a pair of boots purchased by the defendant and Jeffrey Epstein for Minor Victim-2. The defendant states that she would like to examine the boots in order to \"identify the make and provenance of the boots.\" (4/2/21 Letter from Def., Dkt. No. 244 at 11). This appears to be an attempt to use the boots to impeach Minor Victim-2's testimony, shrouded again in a conclusory claim about the need for authentication. For substantially the reasons set forth above with respect to the diary, the Government respectfully submits such a claim is meritless under Nixon.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "However, and although the Government is not obligated to do so, the Government has requested that BSF provide the boots to the Federal Bureau of Investigation (\"FBI\"). BSF has indicated that Minor Victim-2 will likely agree to do so. When the boots are in the FBI's custody, the Government intends to make them available promptly to the defense for examination and use at trial, and will so notify the Court, which should moot Request 10. The Government submits,",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004100",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Carton",
      "Yudong Zhu",
      "Jeffrey Epstein",
      "Minor Victim-2",
      "Nixon"
    ],
    "organizations": [
      "Federal Bureau of Investigation",
      "BSF",
      "Court",
      "Government"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "05/04/21",
      "Oct. 14, 2014",
      "4/2/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 269",
      "No. 13 Cr. 761 (VM)",
      "Dkt. No. 244",
      "DOJ-OGR-00004100"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible handwritten notes or stamps. The document is likely a government submission or response to a defendant's request."
}