{
  "document_metadata": {
    "page_number": "12",
    "document_number": "293",
    "date": "05/25/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 293 Filed 05/25/21 Page 12 of 32\ne ngage in commercial sex acts knowing that [Accuser-4] was under 18\").5 Pursuant to the\nterms of the NPA, the proposed indictment was never returned, and the USAO-SDFL did not\npursue it further, once Epstein pled guilty on June 30, 2008 to Florida state law charges of\nsolicitation of prostitution and procurement of minors to engage in prostitution. (Ex. A, OPR\nReport at i-ii).\nThe similarity of the allegations presented to the SDFL grand jury and those alleged in\nCounts Five and Six of the S2 Indictment is striking and self-evident. The same overt acts,\nincluding the allegations that form the basis for jurisdiction in SDNY over the crimes charged in\nCounts Five and Six, were presented to both grand juries. Furthermore, the proof offered to\ncorroborate Accuser-4's allegations—e.g., cell phone records, FedEx records, message pad\nnotes, etc.—was identical. (See Ex. C at 56:21-57:10). The chart below highlights these\nsimilarities:\n\n| S2 Indictment | SDFL Grand Jury Testimony |\n| --- | --- |\n| Sexual Massages | Sexual Massages |\n| \"On multiple occasions between approximately 2001-2004, [Accuser-4] provided nude massages to Epstein at the Palm Beach Residence, during which Epstein engaged in multiple sex acts with [Accuser-4].\" (S2 Indictment ¶ 9d; see also id. at ¶ 25a). | \"[F]rom 2001 to 2004, [Accuser-4] provided Mr. Epstein with ... over 100 massages and all but three of the massages were sexual[] in nature.\" (Ex. C at 23:19-22). The massages took place in Epstein's Palm Beach residence and Accuser-4 was either nude or partially nude. (Ex. C at 22:20-24:6). |\n| Payment | Payment |\n| \"Epstein or one of his employees ... paid [Accuser-4] hundreds of dollars in cash\" for each massage. (S2 Indictment ¶ 9d; see also id. | \"[Accuser-4] was paid between $200 and $400\" for each massage. (Ex. C at 23:25-24:10). |\n\n5 The government previously denied Ms. Maxwell's request that it produce copies of the proposed 60-count SDFL indictment and the related 82-page prosecution memo to the defense. To resolve any ambiguity about the charges in the proposed SDFL indictment and the evidence underlying the counts related to Accuser-4, Ms. Maxwell requests the Court to order the government to produce both of these documents to the defense.\n8\nDOJ-OGR-00004277",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 293 Filed 05/25/21 Page 12 of 32",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "engage in commercial sex acts knowing that [Accuser-4] was under 18)).5 Pursuant to the\nterms of the NPA, the proposed indictment was never returned, and the USAO-SDFL did not\npursue it further, once Epstein pled guilty on June 30, 2008 to Florida state law charges of\nsolicitation of prostitution and procurement of minors to engage in prostitution. (Ex. A, OPR\nReport at i-ii).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The similarity of the allegations presented to the SDFL grand jury and those alleged in\nCounts Five and Six of the S2 Indictment is striking and self-evident. The same overt acts,\nincluding the allegations that form the basis for jurisdiction in SDNY over the crimes charged in\nCounts Five and Six, were presented to both grand juries. Furthermore, the proof offered to\ncorroborate Accuser-4's allegations—e.g., cell phone records, FedEx records, message pad\nnotes, etc.—was identical. (See Ex. C at 56:21-57:10). The chart below highlights these\nsimilarities:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "| S2 Indictment | SDFL Grand Jury Testimony |\n| --- | --- |\n| Sexual Massages | Sexual Massages |\n| \"On multiple occasions between approximately 2001-2004, [Accuser-4] provided nude massages to Epstein at the Palm Beach Residence, during which Epstein engaged in multiple sex acts with [Accuser-4].\" (S2 Indictment ¶ 9d; see also id. at ¶ 25a). | \"[F]rom 2001 to 2004, [Accuser-4] provided Mr. Epstein with ... over 100 massages and all but three of the massages were sexual[] in nature.\" (Ex. C at 23:19-22). The massages took place in Epstein's Palm Beach residence and Accuser-4 was either nude or partially nude. (Ex. C at 22:20-24:6). |\n| Payment | Payment |\n| \"Epstein or one of his employees ... paid [Accuser-4] hundreds of dollars in cash\" for each massage. (S2 Indictment ¶ 9d; see also id. | \"[Accuser-4] was paid between $200 and $400\" for each massage. (Ex. C at 23:25-24:10). |",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "5 The government previously denied Ms. Maxwell's request that it produce copies of the proposed 60-count SDFL indictment and the related 82-page prosecution memo to the defense. To resolve any ambiguity about the charges in the proposed SDFL indictment and the evidence underlying the counts related to Accuser-4, Ms. Maxwell requests the Court to order the government to produce both of these documents to the defense.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "8\nDOJ-OGR-00004277",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Accuser-4",
      "Ms. Maxwell"
    ],
    "organizations": [
      "USAO-SDFL",
      "SDNY",
      "SDFL"
    ],
    "locations": [
      "Palm Beach",
      "Florida"
    ],
    "dates": [
      "June 30, 2008",
      "2001",
      "2004",
      "05/25/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 293",
      "S2 Indictment",
      "Ex. A",
      "Ex. C",
      "DOJ-OGR-00004277"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Jeffrey Epstein and Ghislaine Maxwell. The text is mostly printed, with no handwritten content or stamps visible. The document quality is clear and legible."
}