{
  "document_metadata": {
    "page_number": "28",
    "document_number": "382",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 28 of 69\nF. Any Reference to Her Should Be Excluded -- Eliminating the Need for a Pseudonym or Other Artifice\nApparently, the government contends that was induced to perform sexual acts by : who has never met, spoken to, or identified Ms. Maxwell. Because this potential witness was only recently disclosed, investigation into her background is ongoing and Ms. Maxwell will need to supplement this response.\nHowever, the government has not made any compelling factual showing about why secrecy is necessary here.\nG. , Hiding Their Identities and Those of Related Witnesses Serves No Legitimate Purpose\nThe government also requests that the identities of various witnesses, , also be shielded form the public because, according to the government, revealing the identity of the witness will reveal the identity of the accuser. As noted supra, Given these facts, pseudonyms for the witnesses is a futile gesture.\nH. The Use of Fake Names is Unfairly Prejudicial to Ms. Maxwell\n\"Cross-examination of a witness is a matter of right.\" Permissible purposes of cross-examination are that the witness may be identified in her community so that independent testimony may be sought and offered of her reputation for veracity in her own neighborhood, that the jury may interpret the testimony by knowledge of the witness's environment, and that facts may be brought out tending to discredit the witness by showing that her testimony was untrue or biased. Alford v. United States, 282 U.S. 687, 691-92 (1931). The Confrontation Clause of the\n20\nDOJ-OGR-00005483",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 28 of 69",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "F. Any Reference to Her Should Be Excluded -- Eliminating the Need for a Pseudonym or Other Artifice",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Apparently, the government contends that was induced to perform sexual acts by : who has never met, spoken to, or identified Ms. Maxwell. Because this potential witness was only recently disclosed, investigation into her background is ongoing and Ms. Maxwell will need to supplement this response.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "However, the government has not made any compelling factual showing about why secrecy is necessary here.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "G. , Hiding Their Identities and Those of Related Witnesses Serves No Legitimate Purpose",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government also requests that the identities of various witnesses, , also be shielded form the public because, according to the government, revealing the identity of the witness will reveal the identity of the accuser. As noted supra, Given these facts, pseudonyms for the witnesses is a futile gesture.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "H. The Use of Fake Names is Unfairly Prejudicial to Ms. Maxwell",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "\"Cross-examination of a witness is a matter of right.\" Permissible purposes of cross-examination are that the witness may be identified in her community so that independent testimony may be sought and offered of her reputation for veracity in her own neighborhood, that the jury may interpret the testimony by knowledge of the witness's environment, and that facts may be brought out tending to discredit the witness by showing that her testimony was untrue or biased. Alford v. United States, 282 U.S. 687, 691-92 (1931). The Confrontation Clause of the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "20",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005483",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "10/29/21",
      "1931"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "382",
      "DOJ-OGR-00005483",
      "282 U.S. 687"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is mostly printed, with some redacted sections. There are no visible stamps or handwritten notes."
}