{
  "document_metadata": {
    "page_number": "13",
    "document_number": "146",
    "date": "02/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 146 Filed 02/04/21 Page 13 of 16\nor Accuser-2, or that there is any causal relationship between the alleged incidents involving Accuser-3 in England and those involving Accuser-1 and Accuser-2 in the United States.\nTo the extent there is any doubt about the scope of the alleged conspiratorial agreement, or how the allegations relating to Accuser-3 are within the scope of that agreement, the Court can resolve the issue by ordering a bill of particulars on these points, as the court did in Hsia.\nHowever, if the government cannot articulate how alleged sexual conduct with a person who never traveled falls within the scope of a conspiracy to cause another individual to travel, then allegations concerning Accuser-3 should be stricken.\nC. The Allegations Regarding Accuser-3 Are Unduly Prejudicial to Ms. Maxwell.\nThere can be no legitimate dispute that the allegations regarding Accuser-3 are inflammatory and unduly prejudicial to Ms. Maxwell. The indictment alleges that Epstein \"sexually abused\" Accuser-3 and that Ms. Maxwell encouraged Accuser-3 to massage Epstein, \"knowing that Epstein intended to sexually abuse\" Accuser-3. Indictment ¶¶ 7c, 11d, 17d. The phrase \"sexual abuse\" connotes criminal activity, even though the alleged conduct may well have been lawful: Accuser-3 was at or above the legal age of consent in England at all relevant times, and the indictment contains no suggestion that the alleged sexual activity involving Accuser-3 was nonconsensual. Regardless of whether the conduct was lawful or unlawful in England, however, few allegations could be more prejudicial to a defendant than allegations that she participated in the \"sexual abuse\" of a teenager. The allegations as to Accuser-3, though irrelevant to the government's conspiracy counts, thus create precisely the prejudicial appearance the government seeks.\nBecause the allegations as to Accuser-3 are both irrelevant to the charges against Ms. Maxwell and unduly prejudicial, they should be stricken as surplusage.\n9\nDOJ-OGR-00002688",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 146 Filed 02/04/21 Page 13 of 16",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "or Accuser-2, or that there is any causal relationship between the alleged incidents involving Accuser-3 in England and those involving Accuser-1 and Accuser-2 in the United States.\nTo the extent there is any doubt about the scope of the alleged conspiratorial agreement, or how the allegations relating to Accuser-3 are within the scope of that agreement, the Court can resolve the issue by ordering a bill of particulars on these points, as the court did in Hsia.\nHowever, if the government cannot articulate how alleged sexual conduct with a person who never traveled falls within the scope of a conspiracy to cause another individual to travel, then allegations concerning Accuser-3 should be stricken.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "C. The Allegations Regarding Accuser-3 Are Unduly Prejudicial to Ms. Maxwell.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "There can be no legitimate dispute that the allegations regarding Accuser-3 are inflammatory and unduly prejudicial to Ms. Maxwell. The indictment alleges that Epstein \"sexually abused\" Accuser-3 and that Ms. Maxwell encouraged Accuser-3 to massage Epstein, \"knowing that Epstein intended to sexually abuse\" Accuser-3. Indictment ¶¶ 7c, 11d, 17d. The phrase \"sexual abuse\" connotes criminal activity, even though the alleged conduct may well have been lawful: Accuser-3 was at or above the legal age of consent in England at all relevant times, and the indictment contains no suggestion that the alleged sexual activity involving Accuser-3 was nonconsensual. Regardless of whether the conduct was lawful or unlawful in England, however, few allegations could be more prejudicial to a defendant than allegations that she participated in the \"sexual abuse\" of a teenager. The allegations as to Accuser-3, though irrelevant to the government's conspiracy counts, thus create precisely the prejudicial appearance the government seeks.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Because the allegations as to Accuser-3 are both irrelevant to the charges against Ms. Maxwell and unduly prejudicial, they should be stricken as surplusage.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "9",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002688",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Accuser-1",
      "Accuser-2",
      "Accuser-3",
      "Ms. Maxwell",
      "Epstein",
      "Hsia"
    ],
    "organizations": [],
    "locations": [
      "England",
      "United States"
    ],
    "dates": [
      "02/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 146",
      "DOJ-OGR-00002688"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ghislaine Maxwell, discussing the allegations against her and the potential prejudice caused by certain allegations."
}