{
  "document_metadata": {
    "page_number": "3",
    "document_number": "269",
    "date": "05/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 269 Filed 05/04/21 Page 3 of 9\nPage 3\nFirst, the defendant has not adequately identified why the diary is relevant beyond the portions of the diary the defense has already received. See Ulbricht, 858 F.3d at 109 (explaining that Rule 17(c) is not appropriate for evidence that is “otherwise procurable” (internal quotation marks omitted)). BSF represents that “all potentially relevant pages were produced from this journal to the Defendant in civil discovery in another matter.” (3/22/21 Letter from BSF, Dkt. No. 191 at 5). The Government also obtained and produced seven pages of the diary to the defendant in discovery. (Mot. for a Bill of Particulars and Pretrial Disclosures, Dkt. No. 148 at 10).\nThe defendant argues that the entire diary is exculpatory because it contains no reference to her. (4/2/21 Letter from Def., Dkt. No. 244 at 9). But the Government and Minor Victim-2 have acknowledged the absence of references to the defendant from the start, and Minor Victim-2 is expected to testify to that fact at trial. (See Gov’t Omnibus Response, Dkt. No. 204 at 187 (citing Mem. in Opp. to Def.’s Renewed Motion for Release, Dkt. No. 100 at 11 n.2.); 3/22/21 Letter from BSF, Dkt. No. 191 at 5). The defendant earlier moved to compel the Government to obtain and produce the diary to her, a motion the Court has denied. (Opinion & Order, Dkt. No. 207 at 29).\nAs the Government explained in its opposition to that motion, the Government understands that Minor Victim-2 stopped writing in her diary shortly after meeting Jeffrey Epstein, so there are no entries regarding her later trip with Epstein, during which she met the defendant. (See Gov’t Omnibus Response, Dkt. No. 204 at 187). The victim provided the Government with her entries relating to Epstein, which the Government in turn produced to the defense. (Id.). The remainder of the diary consists of Minor Victim-2’s unrelated personal diary entries, and the defendant has not explained and cannot explain why she needs to review those entries to establish a fact that the\nDOJ-OGR-00004096",
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      "content": "Case 1:20-cr-00330-PAE Document 269 Filed 05/04/21 Page 3 of 9",
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    {
      "type": "printed",
      "content": "Page 3",
      "position": "header"
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      "type": "printed",
      "content": "First, the defendant has not adequately identified why the diary is relevant beyond the portions of the diary the defense has already received. See Ulbricht, 858 F.3d at 109 (explaining that Rule 17(c) is not appropriate for evidence that is “otherwise procurable” (internal quotation marks omitted)). BSF represents that “all potentially relevant pages were produced from this journal to the Defendant in civil discovery in another matter.” (3/22/21 Letter from BSF, Dkt. No. 191 at 5). The Government also obtained and produced seven pages of the diary to the defendant in discovery. (Mot. for a Bill of Particulars and Pretrial Disclosures, Dkt. No. 148 at 10).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The defendant argues that the entire diary is exculpatory because it contains no reference to her. (4/2/21 Letter from Def., Dkt. No. 244 at 9). But the Government and Minor Victim-2 have acknowledged the absence of references to the defendant from the start, and Minor Victim-2 is expected to testify to that fact at trial. (See Gov’t Omnibus Response, Dkt. No. 204 at 187 (citing Mem. in Opp. to Def.’s Renewed Motion for Release, Dkt. No. 100 at 11 n.2.); 3/22/21 Letter from BSF, Dkt. No. 191 at 5). The defendant earlier moved to compel the Government to obtain and produce the diary to her, a motion the Court has denied. (Opinion & Order, Dkt. No. 207 at 29).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "As the Government explained in its opposition to that motion, the Government understands that Minor Victim-2 stopped writing in her diary shortly after meeting Jeffrey Epstein, so there are no entries regarding her later trip with Epstein, during which she met the defendant. (See Gov’t Omnibus Response, Dkt. No. 204 at 187). The victim provided the Government with her entries relating to Epstein, which the Government in turn produced to the defense. (Id.). The remainder of the diary consists of Minor Victim-2’s unrelated personal diary entries, and the defendant has not explained and cannot explain why she needs to review those entries to establish a fact that the",
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      "type": "printed",
      "content": "DOJ-OGR-00004096",
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  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Minor Victim-2",
      "Ulbricht"
    ],
    "organizations": [
      "Government",
      "BSF",
      "Court"
    ],
    "locations": [],
    "dates": [
      "3/22/21",
      "4/2/21",
      "05/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 269",
      "Dkt. No. 191",
      "Dkt. No. 148",
      "Dkt. No. 244",
      "Dkt. No. 204",
      "Dkt. No. 100",
      "Dkt. No. 207"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}