{
  "document_metadata": {
    "page_number": "215",
    "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 215 of 239\n\nEpstein or the defendant.\"). In other words, the defendant again seeks supposedly exculpatory evidence that does not exist. The defendant offers no basis on which to conclude that this representation is false or that any such evidence does in fact exist. As such, this motion should be denied.\n\nFifth, the defendant asks this Court, again without citing any legal authority, to order the Government to produce copies of all subpoenas it has issued for the defendant's records as part of its investigation in this case. (Def. Mot. 10 at 11). This incredibly broad request is nothing more than a fishing expedition inappropriately seeking the details of investigative requests made through the grand jury process. The defense has cited no legal basis for the Court to direct the Government to provide the defense with copies of the subpoenas themselves (as opposed to records or other materials received in response to such subpoenas), let alone every subpoena issued for the defendant's records during a multi-year and ongoing grand jury investigation. The types of requests issued by the grand jury have no conceivable bearing on the defense or on any motion the defense may seek to bring. The Government has already produced to the defense all discoverable material that it has received in response to subpoenas issued to date during this investigation. In the absence of any legal authority justifying this request, it should be denied. Additionally, for the reasons discussed above in Sections I and IV, the defendant is not entitled to discovery or a hearing relating to her motion to dismiss the Indictment based on the NPA or her motion to suppress subpoena returns.\n\nSixth, the defendant asks the Court to direct the Government to immediately disclose any Brady and Giglio material. (Def. Mot. 10 at 11-13). The motion for disclosure of Brady material should be denied as moot because the Government has conducted a search for any such material and has already disclosed any potentially exculpatory information in its possession of which it is aware.\n\n188\nDOJ-OGR-00003149",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 215 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Epstein or the defendant.\"). In other words, the defendant again seeks supposedly exculpatory evidence that does not exist. The defendant offers no basis on which to conclude that this representation is false or that any such evidence does in fact exist. As such, this motion should be denied.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Fifth, the defendant asks this Court, again without citing any legal authority, to order the Government to produce copies of all subpoenas it has issued for the defendant's records as part of its investigation in this case. (Def. Mot. 10 at 11). This incredibly broad request is nothing more than a fishing expedition inappropriately seeking the details of investigative requests made through the grand jury process. The defense has cited no legal basis for the Court to direct the Government to provide the defense with copies of the subpoenas themselves (as opposed to records or other materials received in response to such subpoenas), let alone every subpoena issued for the defendant's records during a multi-year and ongoing grand jury investigation. The types of requests issued by the grand jury have no conceivable bearing on the defense or on any motion the defense may seek to bring. The Government has already produced to the defense all discoverable material that it has received in response to subpoenas issued to date during this investigation. In the absence of any legal authority justifying this request, it should be denied. Additionally, for the reasons discussed above in Sections I and IV, the defendant is not entitled to discovery or a hearing relating to her motion to dismiss the Indictment based on the NPA or her motion to suppress subpoena returns.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Sixth, the defendant asks the Court to direct the Government to immediately disclose any Brady and Giglio material. (Def. Mot. 10 at 11-13). The motion for disclosure of Brady material should be denied as moot because the Government has conducted a search for any such material and has already disclosed any potentially exculpatory information in its possession of which it is aware.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "188",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003149",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Brady",
      "Giglio"
    ],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00003149"
    ]
  },
  "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 215 of 239."
}