{
  "document_metadata": {
    "page_number": "76",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 76 of 239\ndeath.17 As such, it is neither surprising nor terribly probative of any issue in dispute in this case that Detective Recarey might have testified to a lack of knowledge as to what the victims identified in this Indictment have told the USAO-SDNY. In sum, the defendant has not put \"specific evidence\" before this Court demonstrating that the loss of Detective Recarey's testimony, even if admissible, has caused her actual prejudice. Scala, 388 F. Supp. 2d at 400.\nThe defendant next contends that had the Government brought the charges earlier, she would have interviewed and subpoenaed as witnesses \"the many Epstein employees that were present at the different locations during that three-year period.\" (Def. Mot. 7 at 11). She does not specify which employees she would have called as witnesses, the grounds for contending they are \"lost\" or \"missing,\" whether they would have been willing to testify, or what admissible evidence they would have provided. She merely speculates that the evidence could have helped her defense. This is far from the definite proof of prejudice required to state a due process claim. See United States v. Greer, 956 F. Supp. 525, 528 (D. Vt. 1997) (\"In the context of unavailable witnesses, the defendant must offer some grounds for his belief that the absent witness would have helped his case in a material way.\") (internal quotation marks and citation omitted)).\nThe defendant also argues that \"[m]any potential witnesses have been contacted in relation to this matter and other related litigations,\" noting that \"[s]ignificant numbers of potential witnesses no longer remember when events may have occurred\" or \"who was present.\" (Def. Mot. 7 at 12). Dimming or fading memories over the passage of time are not in themselves sufficient to \"demonstrate that [defendants] cannot receive a fair trial\" or \"justify the dismissal of the indictment.\" Marion, 404 U.S. at 326; Elsbery, 602 F.2d at 1059. Indeed, the fact that the defense described the witnesses as \"potential witnesses\" suggests that she might still call them. Further,\n17 The third victim, Minor Victim-2, was interviewed previously by the FBI. The Government is not aware of Detective Recarey having participated in an interview of Minor Victim-2.",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 76 of 239",
      "position": "header"
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    {
      "type": "printed",
      "content": "death.17 As such, it is neither surprising nor terribly probative of any issue in dispute in this case that Detective Recarey might have testified to a lack of knowledge as to what the victims identified in this Indictment have told the USAO-SDNY. In sum, the defendant has not put \"specific evidence\" before this Court demonstrating that the loss of Detective Recarey's testimony, even if admissible, has caused her actual prejudice. Scala, 388 F. Supp. 2d at 400.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "The defendant next contends that had the Government brought the charges earlier, she would have interviewed and subpoenaed as witnesses \"the many Epstein employees that were present at the different locations during that three-year period.\" (Def. Mot. 7 at 11). She does not specify which employees she would have called as witnesses, the grounds for contending they are \"lost\" or \"missing,\" whether they would have been willing to testify, or what admissible evidence they would have provided. She merely speculates that the evidence could have helped her defense. This is far from the definite proof of prejudice required to state a due process claim. See United States v. Greer, 956 F. Supp. 525, 528 (D. Vt. 1997) (\"In the context of unavailable witnesses, the defendant must offer some grounds for his belief that the absent witness would have helped his case in a material way.\") (internal quotation marks and citation omitted)).",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "The defendant also argues that \"[m]any potential witnesses have been contacted in relation to this matter and other related litigations,\" noting that \"[s]ignificant numbers of potential witnesses no longer remember when events may have occurred\" or \"who was present.\" (Def. Mot. 7 at 12). Dimming or fading memories over the passage of time are not in themselves sufficient to \"demonstrate that [defendants] cannot receive a fair trial\" or \"justify the dismissal of the indictment.\" Marion, 404 U.S. at 326; Elsbery, 602 F.2d at 1059. Indeed, the fact that the defense described the witnesses as \"potential witnesses\" suggests that she might still call them. Further,",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "17 The third victim, Minor Victim-2, was interviewed previously by the FBI. The Government is not aware of Detective Recarey having participated in an interview of Minor Victim-2.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "49",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003010",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Detective Recarey",
      "Minor Victim-2"
    ],
    "organizations": [
      "FBI",
      "USAO-SDNY"
    ],
    "locations": [
      "D. Vt."
    ],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00003010"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with a clear structure and formatting. There are no visible stamps or handwritten annotations. The document quality is good, with no apparent damage or redactions."
}