{
  "document_metadata": {
    "page_number": "10",
    "document_number": "385",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 385 Filed 10/29/21 Page 10 of 12\n\nIndictment. It is hard to imagine how is \"direct evidence\" of a conspiracy to transport, entice or traffic minors for sexual abuse.\n\nAs to the witness referenced in the Letter, the Letter makes clear that the witness worked for Mr. Epstein from , after the conclusion of the charged conspiracy in 2004. Given the timing of her stated employment, it also begs the question how her testimony, reference to unspecified documents or scheduling of unspecified massages, \"among other things,\" could be direct evidence of a conspiracy that ended a year earlier.\n\nBut because Ms. Maxwell has had insufficient time to investigate these newly-disclosed materials, she is unable to file a motion challenging their admissibility at this time.\n\nAs to the newly disclosed witness, the Government produced on October 12, 2021 approximately 400 pages of interview reports, notes, documents, and other materials related to that witness. Ms. Maxwell is unable to review, investigate, or rebut the admissibility of all of the referenced materials by the October 18, 2021 due date for motions in limine, and requests an additional two weeks to file her brief addressing the proffered 404(b) evidence.\n\nCONCLUSION\n\nThe Government has been on notice of the amendments to Rule 404(b) since at least January 25, 2021. See Dkt. 146 at 10.1 The Government was prepared to disclose their Rule\n\n1 Indeed, the Government argued in their response to Ms. Maxwell's pretrial motions that certain evidence pertaining to Accuser-3 would be admissible under Rule 404(b); yet the deadline to provide Notice of an intent to offer that evidence at trial under the rule has come and gone. See Dkt. 204 at 165-169. Ms. Maxwell today moves separately to exclude the evidence pertaining to Accuser-3.\n\n7\nDOJ-OGR-00005619",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 385 Filed 10/29/21 Page 10 of 12",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Indictment. It is hard to imagine how is \"direct evidence\" of a conspiracy to transport, entice or traffic minors for sexual abuse.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "As to the witness referenced in the Letter, the Letter makes clear that the witness worked for Mr. Epstein from , after the conclusion of the charged conspiracy in 2004. Given the timing of her stated employment, it also begs the question how her testimony, reference to unspecified documents or scheduling of unspecified massages, \"among other things,\" could be direct evidence of a conspiracy that ended a year earlier.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "But because Ms. Maxwell has had insufficient time to investigate these newly-disclosed materials, she is unable to file a motion challenging their admissibility at this time.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As to the newly disclosed witness, the Government produced on October 12, 2021 approximately 400 pages of interview reports, notes, documents, and other materials related to that witness. Ms. Maxwell is unable to review, investigate, or rebut the admissibility of all of the referenced materials by the October 18, 2021 due date for motions in limine, and requests an additional two weeks to file her brief addressing the proffered 404(b) evidence.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "CONCLUSION",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government has been on notice of the amendments to Rule 404(b) since at least January 25, 2021. See Dkt. 146 at 10.1 The Government was prepared to disclose their Rule",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 Indeed, the Government argued in their response to Ms. Maxwell's pretrial motions that certain evidence pertaining to Accuser-3 would be admissible under Rule 404(b); yet the deadline to provide Notice of an intent to offer that evidence at trial under the rule has come and gone. See Dkt. 204 at 165-169. Ms. Maxwell today moves separately to exclude the evidence pertaining to Accuser-3.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "7",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005619",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Mr. Epstein",
      "Accuser-3"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "October 12, 2021",
      "October 18, 2021",
      "January 25, 2021",
      "2004"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 385",
      "Dkt. 146",
      "Dkt. 204"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, with redactions in several places. The text discusses the admissibility of certain evidence and the timing of disclosures made by the Government."
}