{
  "document_metadata": {
    "page_number": "8",
    "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 8 of 12\ncharged crimes [and (ii)] her [unspecified] role in scheduling sexualized massages for Jeffrey Epstein with underage girls,\" apparently in . This is hardly the type of \"identif[ied]\" evidence the Rule contemplates. What \"documentary evidence\" will she testify about? What \"role\" did she play in scheduling massages after the conclusion of the charged conspiracy? For what purpose will she testify to it? Are there other topics covered by the language \"among other things\" that the Government submits is admissible under Rule 404(b)? What is it? What is the purpose of it? Will it be offered to prove Ms. Maxwell's \"intent, preparation, plan, knowledge, identity and/or absence of mistake of [sic] accident\" or something else? How is it permissible non-propensity evidence?\n\nFinally, by failing to identify the numerous exhibits that fall after the period of the conspiracy in the Rule 404(b) Letter, the Government has also waived any right to argue that those documents should be admitted under the rule as well.\n\nThe entire point of the change to Rule 404(b), and this Court's scheduling Order, is to permit Ms. Maxwell to investigate, analyze, dispute, move in limine if appropriate, or rebut the proffered Rule 404(b) evidence. There is nothing in Rule 404(b) that excuses the required Notice in the event the Government only offers the evidence \"in the alternative\" under the rule.\nBy disregarding the requirements of Rule 404(b), the Government has chosen to deprive Ms. Maxwell of her right to dispute the admissibility of this evidence.\n\nII. Should the Government's Failure Be Excused, Ms. Maxwell Requests an Opportunity to Rebut any Proffered Non-Propensity Purpose and Basis\n\nBecause the Government has not identified the non-propensity purpose nor reasoning underlying the admission of any Rule 404(b) evidence, the defense is left without \"sufficient time for an independent investigation that might surface evidence that refutes, mitigates, or places the other act in a different light,\" and the Court will not have sufficient \"time to consider\n\n5\nDOJ-OGR-00005617",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 385 Filed 10/29/21 Page 8 of 12",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "charged crimes [and (ii)] her [unspecified] role in scheduling sexualized massages for Jeffrey Epstein with underage girls,\" apparently in . This is hardly the type of \"identif[ied]\" evidence the Rule contemplates. What \"documentary evidence\" will she testify about? What \"role\" did she play in scheduling massages after the conclusion of the charged conspiracy? For what purpose will she testify to it? Are there other topics covered by the language \"among other things\" that the Government submits is admissible under Rule 404(b)? What is it? What is the purpose of it? Will it be offered to prove Ms. Maxwell's \"intent, preparation, plan, knowledge, identity and/or absence of mistake of [sic] accident\" or something else? How is it permissible non-propensity evidence?",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Finally, by failing to identify the numerous exhibits that fall after the period of the conspiracy in the Rule 404(b) Letter, the Government has also waived any right to argue that those documents should be admitted under the rule as well.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "The entire point of the change to Rule 404(b), and this Court's scheduling Order, is to permit Ms. Maxwell to investigate, analyze, dispute, move in limine if appropriate, or rebut the proffered Rule 404(b) evidence. There is nothing in Rule 404(b) that excuses the required Notice in the event the Government only offers the evidence \"in the alternative\" under the rule.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "By disregarding the requirements of Rule 404(b), the Government has chosen to deprive Ms. Maxwell of her right to dispute the admissibility of this evidence.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "II. Should the Government's Failure Be Excused, Ms. Maxwell Requests an Opportunity to Rebut any Proffered Non-Propensity Purpose and Basis",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Because the Government has not identified the non-propensity purpose nor reasoning underlying the admission of any Rule 404(b) evidence, the defense is left without \"sufficient time for an independent investigation that might surface evidence that refutes, mitigates, or places the other act in a different light,\" and the Court will not have sufficient \"time to consider",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005617",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Ms. Maxwell"
    ],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [],
    "dates": [
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 385",
      "DOJ-OGR-00005617"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ghislaine Maxwell, discussing the admissibility of evidence under Rule 404(b)."
}