{
  "document_metadata": {
    "page_number": "144",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 144 of 239\n\ntrial record—that the questions were fundamentally ambiguous, and the defendant's answers were truthful and immaterial. (Def. Mot. 5). To the contrary, the Government expects to prove at trial that the defendant understood the questions and that her answers were both false and materially so. This case does not present the narrow circumstances in which a court can and should dismiss perjury counts, let alone do so before trial.\n\nA. Factual Background\n\nOn July 7, 2008, following the USAO-SDFL entering into the non-prosecution agreement with Epstein, two minors filed a petition under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, alleging that the prosecutors violated their rights under that statute. See Doe v. United States, 08 Civ. 80736 (S.D.F.L). See generally Doe No. 1. v. United States, 749 F.3d 999, 1002 (11th Cir. 2014) (describing the background of the suit). On December 30, 2014, Virginia Roberts Giuffre moved to join the petition, alleging that the USAO-SDFL had also violated her CVRA rights. See Doe, No 08 Civ. 80736, Dkt. No. 279.45 In her motion for joinder, Giuffre described the defendant as “one of the main women' Epstein used to 'procure under-aged girls for sexual activities,'” and as a “primary co-conspirator' with Epstein in his scheme. See Giuffre v. Maxwell, No. 18-2868 (2d Cir. 2019), Dkt. No. 287 at 10 (containing the unsealed summary judgment opinion from 15 Civ. 7433 (LAP)). Among other allegations, Giuffre alleged that the defendant “'persuaded' [her] to go to Epstein's mansion,” and, “when Giuffre began giving Epstein a massage, [he] and [the defendant] 'turned it into a sexual encounter.'” Id. at 11. Giuffre alleged that the defendant also “'participated[ed] in the sexual abuse'” of others. Id. A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things,\n\n45 Giuffre filed a corrected motion on January 2, 2015. See Doe, No. 08 Civ. 80736, Dkt. No. 280. The court later struck the original motion, sealed the corrected motion, and ordered filing of a redacted version of the corrected motion. See id., Dkt. No. 325 (Apr. 7, 2015).\n\n117\nDOJ-OGR-00003078",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 144 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "trial record—that the questions were fundamentally ambiguous, and the defendant's answers were truthful and immaterial. (Def. Mot. 5). To the contrary, the Government expects to prove at trial that the defendant understood the questions and that her answers were both false and materially so. This case does not present the narrow circumstances in which a court can and should dismiss perjury counts, let alone do so before trial.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "A. Factual Background",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "On July 7, 2008, following the USAO-SDFL entering into the non-prosecution agreement with Epstein, two minors filed a petition under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, alleging that the prosecutors violated their rights under that statute. See Doe v. United States, 08 Civ. 80736 (S.D.F.L). See generally Doe No. 1. v. United States, 749 F.3d 999, 1002 (11th Cir. 2014) (describing the background of the suit). On December 30, 2014, Virginia Roberts Giuffre moved to join the petition, alleging that the USAO-SDFL had also violated her CVRA rights. See Doe, No 08 Civ. 80736, Dkt. No. 279.45 In her motion for joinder, Giuffre described the defendant as “one of the main women' Epstein used to 'procure under-aged girls for sexual activities,'” and as a “primary co-conspirator' with Epstein in his scheme. See Giuffre v. Maxwell, No. 18-2868 (2d Cir. 2019), Dkt. No. 287 at 10 (containing the unsealed summary judgment opinion from 15 Civ. 7433 (LAP)). Among other allegations, Giuffre alleged that the defendant “'persuaded' [her] to go to Epstein's mansion,” and, “when Giuffre began giving Epstein a massage, [he] and [the defendant] 'turned it into a sexual encounter.'” Id. at 11. Giuffre alleged that the defendant also “'participated[ed] in the sexual abuse'” of others. Id. A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "45 Giuffre filed a corrected motion on January 2, 2015. See Doe, No. 08 Civ. 80736, Dkt. No. 280. The court later struck the original motion, sealed the corrected motion, and ordered filing of a redacted version of the corrected motion. See id., Dkt. No. 325 (Apr. 7, 2015).",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "117",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003078",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Virginia Roberts Giuffre",
      "Maxwell",
      "Ross Gow"
    ],
    "organizations": [
      "USAO-SDFL",
      "DOJ"
    ],
    "locations": [
      "S.D.F.L",
      "LAP"
    ],
    "dates": [
      "July 7, 2008",
      "December 30, 2014",
      "January 2, 2015",
      "April 7, 2015",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "08 Civ. 80736",
      "No. 18-2868",
      "15 Civ. 7433",
      "Dkt. No. 279",
      "Dkt. No. 287",
      "Dkt. No. 280",
      "Dkt. No. 325",
      "DOJ-OGR-00003078"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving a defendant accused of perjury. The text discusses the factual background of the case and includes references to various court documents and proceedings."
}