{
  "document_metadata": {
    "page_number": "4",
    "document_number": "389",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 389 Filed 10/29/21 Page 4 of 11\n\nGhislaine Maxwell respectfully moves in limine to exclude evidence of any alleged false statements by Ms. Maxwell in her 2016 civil depositions, as well as any other evidence related to the severed perjury counts, to prove a purported attempt by Ms. Maxwell to \"conceal\" her involvement in the other offenses charged in the superseding indictment. Ms. Maxwell also respectfully moves the Court to redact from the superseding indictment the perjury counts and any allegations that Ms. Maxwell made false statements to \"conceal\" her involvement in Jeffrey Epstein's crimes. Ms. Maxwell requests this relief pursuant to the Court's prior severance ruling and Federal Rule of Evidence 403. See 4/16/2021 Op. and Order (Dkt. 207) at 23-26; Fed. R. Evid. 403.\n\nBACKGROUND\n\nThe Court has already ruled that the perjury counts must be severed because trying the perjury counts with the other counts in the indictment would risk admitting evidence that would be \"unduly prejudicial\" to Ms. Maxwell, would \"compromise [Ms.] Maxwell's right to the counsel of her choice,\" and would \"risk an unfair trial.\" 4/16/2021 Op. and Order (Dkt. 207) at 23-24. In particular, the Court recognized that introducing evidence related to the perjury charges would expose the jury to other acts of alleged sexual abuse that are not charged in the indictment, as well as evidence of an unrelated civil lawsuit by a separate accuser, that could significantly sway the jury's verdict on the other counts in the indictment.\n\n[Trying the perjury counts with the other counts] would introduce unrelated allegations of sexual abuse, which would potentially expose the jury to evidence that might otherwise not be admissible. In particular, a joint trial would potentially expose the jury to a wider swath of information regarding civil litigation against Epstein that is remote from Maxwell's charged conduct. This presents a significant risk that the jury will cumulate the evidence of the various crimes charged and find guilt when, if considered separately, it would not do so.\n\nDOJ-OGR-00005705",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 389 Filed 10/29/21 Page 4 of 11",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Ghislaine Maxwell respectfully moves in limine to exclude evidence of any alleged false statements by Ms. Maxwell in her 2016 civil depositions, as well as any other evidence related to the severed perjury counts, to prove a purported attempt by Ms. Maxwell to \"conceal\" her involvement in the other offenses charged in the superseding indictment. Ms. Maxwell also respectfully moves the Court to redact from the superseding indictment the perjury counts and any allegations that Ms. Maxwell made false statements to \"conceal\" her involvement in Jeffrey Epstein's crimes. Ms. Maxwell requests this relief pursuant to the Court's prior severance ruling and Federal Rule of Evidence 403. See 4/16/2021 Op. and Order (Dkt. 207) at 23-26; Fed. R. Evid. 403.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "BACKGROUND",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Court has already ruled that the perjury counts must be severed because trying the perjury counts with the other counts in the indictment would risk admitting evidence that would be \"unduly prejudicial\" to Ms. Maxwell, would \"compromise [Ms.] Maxwell's right to the counsel of her choice,\" and would \"risk an unfair trial.\" 4/16/2021 Op. and Order (Dkt. 207) at 23-24. In particular, the Court recognized that introducing evidence related to the perjury charges would expose the jury to other acts of alleged sexual abuse that are not charged in the indictment, as well as evidence of an unrelated civil lawsuit by a separate accuser, that could significantly sway the jury's verdict on the other counts in the indictment.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "[Trying the perjury counts with the other counts] would introduce unrelated allegations of sexual abuse, which would potentially expose the jury to evidence that might otherwise not be admissible. In particular, a joint trial would potentially expose the jury to a wider swath of information regarding civil litigation against Epstein that is remote from Maxwell's charged conduct. This presents a significant risk that the jury will cumulate the evidence of the various crimes charged and find guilt when, if considered separately, it would not do so.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005705",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell",
      "Jeffrey Epstein",
      "Ms. Maxwell"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "10/29/21",
      "4/16/2021",
      "2016"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 389",
      "Dkt. 207",
      "DOJ-OGR-00005705"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 4 of 11."
}