{
  "document_metadata": {
    "page_number": "8",
    "document_number": "307",
    "date": "06/25/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 307 Filed 06/25/21 Page 8 of 21 inculpatory. Fisher, 425 U.S. at 410–11. This is no such case. The existence of deposition transcripts in Maxwell's civil case is not inculpatory. It is the content of those transcripts that is at issue. In the face of these straightforward precedents, Maxwell relies primarily on a single district court case decided the year before the Second Circuit's decision in Andover that quashed a subpoena for deposition testimony covered by a civil protective order. See Dkt. No. 140, at 16–17 (citing United States v. Oshatz, 700 F. Supp. 696 (S.D.N.Y. 1988)); Dkt. No. 212, at 12– 13 (same). Oshatz does not suggest that the use of civil deposition testimony in a subsequent criminal trial would violate a defendant's right against compelled self-incrimination—and if it did, that view would be plainly inconsistent with the Second Circuit's later, precedential opinions. Instead, the case simply describes the standard for whether a court should modify a protective order to allow a government subpoena. Maxwell cites no case in which a court has suppressed evidence because another court erred in modifying a protective order. Even if Maxwell were right that the protective order should not have been modified, it would not transform her earlier deposition testimony into the product of coercion. The Government would also be entitled to use Maxwell's deposition testimony against her in her perjury trial notwithstanding any violation of her right against compelled self- incrimination. The Supreme Court has held that a defendant may be prosecuted for false statements in unlawfully compelled testimony. See United States v. Wong, 431 U.S. 174, 179 (1977); United States v. Knox, 396 U.S. 77, 82 (1969). As in Knox, Maxwell seeks to suppress her deposition transcripts not because they are inculpatory “for a prior or subsequent criminal act” but because her statements in those depositions were themselves allegedly criminal. Knox, 8 DOJ-OGR-00004792",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 307 Filed 06/25/21 Page 8 of 21",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "inculpatory. Fisher, 425 U.S. at 410–11. This is no such case. The existence of deposition transcripts in Maxwell's civil case is not inculpatory. It is the content of those transcripts that is at issue. In the face of these straightforward precedents, Maxwell relies primarily on a single district court case decided the year before the Second Circuit's decision in Andover that quashed a subpoena for deposition testimony covered by a civil protective order. See Dkt. No. 140, at 16–17 (citing United States v. Oshatz, 700 F. Supp. 696 (S.D.N.Y. 1988)); Dkt. No. 212, at 12– 13 (same). Oshatz does not suggest that the use of civil deposition testimony in a subsequent criminal trial would violate a defendant's right against compelled self-incrimination—and if it did, that view would be plainly inconsistent with the Second Circuit's later, precedential opinions. Instead, the case simply describes the standard for whether a court should modify a protective order to allow a government subpoena. Maxwell cites no case in which a court has suppressed evidence because another court erred in modifying a protective order. Even if Maxwell were right that the protective order should not have been modified, it would not transform her earlier deposition testimony into the product of coercion. The Government would also be entitled to use Maxwell's deposition testimony against her in her perjury trial notwithstanding any violation of her right against compelled self- incrimination. The Supreme Court has held that a defendant may be prosecuted for false statements in unlawfully compelled testimony. See United States v. Wong, 431 U.S. 174, 179 (1977); United States v. Knox, 396 U.S. 77, 82 (1969). As in Knox, Maxwell seeks to suppress her deposition transcripts not because they are inculpatory “for a prior or subsequent criminal act” but because her statements in those depositions were themselves allegedly criminal. Knox,",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "8",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004792",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Fisher"
    ],
    "organizations": [
      "Supreme Court",
      "Second Circuit",
      "Government"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "06/25/21",
      "1977",
      "1969",
      "1988"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "307",
      "Dkt. No. 140",
      "Dkt. No. 212",
      "425 U.S.",
      "410-11",
      "700 F. Supp. 696",
      "431 U.S. 174",
      "396 U.S. 77",
      "DOJ-OGR-00004792"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Maxwell, with discussions on legal precedents and the use of deposition testimony in criminal trials. The text is well-formatted and clear, with no visible redactions or damage."
}