{
  "document_metadata": {
    "page_number": "184",
    "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 184 of 239 against her. The Indictment also cites the relevant state criminal statute under which the defendant is charged constituting \"sexual activity\" within the language of both § 2422 and § 2243, specifically, violations of New York Penal Law § 130.55. Indictment ¶¶ 11(b), 13, 17(b), 19. The defendant cites no authority for her suggestion that by providing additional detail regarding how the defendant committed the charged crimes, the Government is somehow required to provide even more specificity beyond the basic elements of the crimes charged. Absent any such authority, and where there is no suggestion that the Indictment fails to allege the essential elements of each crime charged, there is no basis to dismiss any of the counts in the Indictment. For the foregoing reasons, the defendant's sufficiency challenges to the Indictment fail as a matter of law, and her motion to dismiss Counts One through Four should be denied. VIII. There Is No Basis to Strike Any Portion of the Indictment The defendant moves to strike any reference to Minor Victim-3 from the Indictment, claiming that—contrary to the plain terms of the Indictment—the events involving Minor Victim-3 are unrelated to the conspiracies charged in Counts One and Three and that some of that the allegations regarding Minor Victim-3 are unduly prejudicial. (Def. Mot. 6). The motion is baseless. First, as the Indictment itself makes clear, the defendant's and Epstein's interactions with Minor Victim-3 were part of a broader scheme and agreement to entice and transport minor victims with intent to commit illegal sex acts. Even if Minor Victim-3 was not ultimately transported as a minor, the core of a conspiracy is an agreement to engage in criminal conduct; there is no legal requirement that the agreed upon crime be completed. Although Minor Victim-3's experiences cannot alone form the basis of a timely substantive charge, both charged conspiracies include timely overt acts, and it is well established that a charged conspiracy can encompass otherwise time-barred acts so long as at least one overt act in furtherance of the 157 DOJ-OGR-00003118",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 184 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "against her. The Indictment also cites the relevant state criminal statute under which the defendant is charged constituting \"sexual activity\" within the language of both § 2422 and § 2243, specifically, violations of New York Penal Law § 130.55. Indictment ¶¶ 11(b), 13, 17(b), 19. The defendant cites no authority for her suggestion that by providing additional detail regarding how the defendant committed the charged crimes, the Government is somehow required to provide even more specificity beyond the basic elements of the crimes charged. Absent any such authority, and where there is no suggestion that the Indictment fails to allege the essential elements of each crime charged, there is no basis to dismiss any of the counts in the Indictment. For the foregoing reasons, the defendant's sufficiency challenges to the Indictment fail as a matter of law, and her motion to dismiss Counts One through Four should be denied.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIII. There Is No Basis to Strike Any Portion of the Indictment",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant moves to strike any reference to Minor Victim-3 from the Indictment, claiming that—contrary to the plain terms of the Indictment—the events involving Minor Victim-3 are unrelated to the conspiracies charged in Counts One and Three and that some of that the allegations regarding Minor Victim-3 are unduly prejudicial. (Def. Mot. 6). The motion is baseless. First, as the Indictment itself makes clear, the defendant's and Epstein's interactions with Minor Victim-3 were part of a broader scheme and agreement to entice and transport minor victims with intent to commit illegal sex acts. Even if Minor Victim-3 was not ultimately transported as a minor, the core of a conspiracy is an agreement to engage in criminal conduct; there is no legal requirement that the agreed upon crime be completed. Although Minor Victim-3's experiences cannot alone form the basis of a timely substantive charge, both charged conspiracies include timely overt acts, and it is well established that a charged conspiracy can encompass otherwise time-barred acts so long as at least one overt act in furtherance of the",
      "position": "middle"
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    {
      "type": "printed",
      "content": "157",
      "position": "footer"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00003118",
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  ],
  "entities": {
    "people": [
      "Epstein",
      "Minor Victim-3"
    ],
    "organizations": [],
    "locations": [
      "New York"
    ],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00003118"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 184 of 239."
}