{
  "document_metadata": {
    "page_number": "39",
    "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 39 of 84\n\nonly highlights that this evidence does “not involve conduct any more sensational or disturbing than the crimes with which [the defendant] was charged,” which weighs in favor of admitting these exhibits under Rule 404(b)(2). United States v. Roldan-Zapata, 916 F.2d 795, 804 (2d Cir. 1990).\n\nb. Testimony of Employee-1\nEmployee-1 worked as a personal assistant for Epstein for approximately .\n(October 11, 2021 Letter, Def. Mot. 2 Ex. A at 1). During that time, Employee-1 reported directly to another employee (“Employee-2”), who worked for Epstein during the timeframe of the charged conspiracy, and who is referenced in the Second Superseding Indictment (the Indictment”). (ECF No. 187, ¶¶ 6, 7(b)). The Government expects that Employee-1 will testify about Employee-1’s observations of the close relationship between the defendant and Epstein. Indeed, Employee-1 will testify that Employee-1 worked out of the defendant’s townhouse in Manhattan during the weeks that Employee-1 worked in New York City. The Government also expects Employee-1 to testify about her observations at Epstein’s properties, including observations of minor girls at the properties, as well as her knowledge of Epstein’s practice to arrange multiple sexualized massages per day. In addition, although Employee-1’s employment post-dates the defendant’s conduct with the victims in this case, Employee-1 became familiar with certain items in Epstein’s residences during her tenure there, and thus Employee-1 will authenticate certain exhibits relating to the Minor Victims. Finally, the Government expects\n\n\n\n38\n\nDOJ-OGR-00005822",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 39 of 84",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "only highlights that this evidence does “not involve conduct any more sensational or disturbing than the crimes with which [the defendant] was charged,” which weighs in favor of admitting these exhibits under Rule 404(b)(2). United States v. Roldan-Zapata, 916 F.2d 795, 804 (2d Cir. 1990).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "b. Testimony of Employee-1\nEmployee-1 worked as a personal assistant for Epstein for approximately .\n(October 11, 2021 Letter, Def. Mot. 2 Ex. A at 1). During that time, Employee-1 reported directly to another employee (“Employee-2”), who worked for Epstein during the timeframe of the charged conspiracy, and who is referenced in the Second Superseding Indictment (the Indictment”). (ECF No. 187, ¶¶ 6, 7(b)). The Government expects that Employee-1 will testify about Employee-1’s observations of the close relationship between the defendant and Epstein. Indeed, Employee-1 will testify that Employee-1 worked out of the defendant’s townhouse in Manhattan during the weeks that Employee-1 worked in New York City. The Government also expects Employee-1 to testify about her observations at Epstein’s properties, including observations of minor girls at the properties, as well as her knowledge of Epstein’s practice to arrange multiple sexualized massages per day. In addition, although Employee-1’s employment post-dates the defendant’s conduct with the victims in this case, Employee-1 became familiar with certain items in Epstein’s residences during her tenure there, and thus Employee-1 will authenticate certain exhibits relating to the Minor Victims. Finally, the Government expects",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "38",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005822",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Employee-1",
      "Employee-2",
      "Epstein",
      "Roldan-Zapata"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [
      "Manhattan",
      "New York City"
    ],
    "dates": [
      "October 11, 2021",
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "397",
      "ECF No. 187",
      "DOJ-OGR-00005822"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions. The content discusses the testimony of Employee-1 and her expected testimony regarding Epstein and the defendant."
}