{
  "document_metadata": {
    "page_number": "25",
    "document_number": "295",
    "date": "05/25/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 25 of 26\n\n(2d Cir. 2001) (prosecution must produce Giglio material \"in time for its effective use at trial\"). Impeachment material simply does not warrant immediate disclosure. See, e.g., United States v. Nixon, 418 U.S. 683, 701 (1974) (\"Generally, the need for evidence to impeach witnesses is insufficient to require its production in advance of trial.\"); United States v. Campo Flores, No. 15 Cr. 765 (PAC), 2016 WL 5946472, at *11 (S.D.N.Y. Oct. 12, 2016) (\"The Government has represented that it will make impeachment material relating to its anticipated witnesses available . . . ten days before trial. There is no need to depart from the customary rule in this district of disclosure shortly before trial.\")\n\nAlthough not essential to the timing analysis here, the Government notes that the defense motion overstates the significance of the particular statements Minor Victim-4 made during the USAO-SDFL's investigation. The Government understands from its more recent interviews with Minor Victim-4, the notes of which the Government will produce to the defense as part of Minor Victim-4's Giglio and Jencks Act material, that she was not asked any questions about the defendant during her only interview in connection with the USAO-SDFL's investigation, which focused instead on Epstein and another of Epstein's employees. Notably, though, when Minor Victim-4 was deposed in connection with a civil lawsuit after she was interviewed during the USAO-SDFL's investigation but more than a decade before the defendant was indicted in this case, Minor Victim-4 affirmatively stated that the defendant was one of the individuals who scheduled her massage appointments with Epstein. Minor Victim-4 was not asked any follow-up questions about the defendant during that deposition, but her prior consistent statement regarding the defendant's involvement in scheduling her massages severely undercuts the defense's suggestion that Minor Victim-4 entirely fabricated the defendant's role in Epstein's scheme after the defendant was indicted in 2020. The Government fully intends to provide the defense with all\n\n21\n\nDOJ-OGR-00004732",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 25 of 26",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "(2d Cir. 2001) (prosecution must produce Giglio material \"in time for its effective use at trial\"). Impeachment material simply does not warrant immediate disclosure. See, e.g., United States v. Nixon, 418 U.S. 683, 701 (1974) (\"Generally, the need for evidence to impeach witnesses is insufficient to require its production in advance of trial.\"); United States v. Campo Flores, No. 15 Cr. 765 (PAC), 2016 WL 5946472, at *11 (S.D.N.Y. Oct. 12, 2016) (\"The Government has represented that it will make impeachment material relating to its anticipated witnesses available . . . ten days before trial. There is no need to depart from the customary rule in this district of disclosure shortly before trial.\")",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Although not essential to the timing analysis here, the Government notes that the defense motion overstates the significance of the particular statements Minor Victim-4 made during the USAO-SDFL's investigation. The Government understands from its more recent interviews with Minor Victim-4, the notes of which the Government will produce to the defense as part of Minor Victim-4's Giglio and Jencks Act material, that she was not asked any questions about the defendant during her only interview in connection with the USAO-SDFL's investigation, which focused instead on Epstein and another of Epstein's employees. Notably, though, when Minor Victim-4 was deposed in connection with a civil lawsuit after she was interviewed during the USAO-SDFL's investigation but more than a decade before the defendant was indicted in this case, Minor Victim-4 affirmatively stated that the defendant was one of the individuals who scheduled her massage appointments with Epstein. Minor Victim-4 was not asked any follow-up questions about the defendant during that deposition, but her prior consistent statement regarding the defendant's involvement in scheduling her massages severely undercuts the defense's suggestion that Minor Victim-4 entirely fabricated the defendant's role in Epstein's scheme after the defendant was indicted in 2020. The Government fully intends to provide the defense with all",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "21",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004732",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Minor Victim-4",
      "Epstein",
      "Nixon"
    ],
    "organizations": [
      "USAO-SDFL",
      "DOJ"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "05/25/21",
      "Oct. 12, 2016",
      "2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 295",
      "No. 15 Cr. 765 (PAC)",
      "DOJ-OGR-00004732"
    ]
  },
  "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 25 of 26."
}