{
  "document_metadata": {
    "page_number": "7",
    "document_number": "336",
    "date": "09/07/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page 7 of 10 Now claims she was abused by Epstein and Maxwell, and See Indictment ¶ 7(a); Ms. Maxwell seeks any notes of Mr. Edwards or Mr. Pottinger's communications with or her counsel6 because of their obvious exculpatory value and in order to authenticate them prior to trial. As described above, Mr. Edwards and Mr. Pottinger both met with Maria Farmer, sister of alleged victim-2 Annie Farmer, in or about June 2016, and purportedly were provided access to physical evidence documenting the Farmers' claims. Ms. Maxwell seeks to inspect any such physical evidence in advance of trial, as well as their notes of those meetings, in order to test the authenticity of the materials and to rebut it. With regard to their clients, and Ms. Giuffre, the proposed subpoena seeks any physical evidence in Mr. Edwards and Mr. Pottinger's possession and any non-privileged notes of their interactions. Finally, Mr. Edwards and Mr. Pottinger have publicly identified themselves as having participated in the crafting of the Epstein Victims Compensation Program and representing some women in submissions to that program, including . Nixon Factors As to Items 1-5, we know that these lawyers communicated with SDNY Assistant U.S. Attorneys; the time frame is definite, 2015 to present, and the requests are limited to a discrete 6In the notes of the meeting with Ms. Kramer, it appears that was then represented by attorney .",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 336 Filed 09/07/21 Page 7 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Now claims she was abused by Epstein and Maxwell, and See Indictment ¶ 7(a); Ms. Maxwell seeks any notes of Mr. Edwards or Mr. Pottinger's communications with or her counsel6 because of their obvious exculpatory value and in order to authenticate them prior to trial.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "As described above, Mr. Edwards and Mr. Pottinger both met with Maria Farmer, sister of alleged victim-2 Annie Farmer, in or about June 2016, and purportedly were provided access to physical evidence documenting the Farmers' claims. Ms. Maxwell seeks to inspect any such physical evidence in advance of trial, as well as their notes of those meetings, in order to test the authenticity of the materials and to rebut it.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "With regard to their clients, and Ms. Giuffre, the proposed subpoena seeks any physical evidence in Mr. Edwards and Mr. Pottinger's possession and any non-privileged notes of their interactions.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, Mr. Edwards and Mr. Pottinger have publicly identified themselves as having participated in the crafting of the Epstein Victims Compensation Program and representing some women in submissions to that program, including .",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Nixon Factors As to Items 1-5, we know that these lawyers communicated with SDNY Assistant U.S. Attorneys; the time frame is definite, 2015 to present, and the requests are limited to a discrete",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "6In the notes of the meeting with Ms. Kramer, it appears that was then represented by attorney .",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Maxwell",
      "Mr. Edwards",
      "Mr. Pottinger",
      "Maria Farmer",
      "Annie Farmer",
      "Ms. Giuffre",
      "Ms. Kramer"
    ],
    "organizations": [
      "SDNY"
    ],
    "locations": [],
    "dates": [
      "09/07/21",
      "2015",
      "2016"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 336",
      "¶ 7(a)"
    ]
  },
  "additional_notes": "The document contains redactions, likely for sensitive or personal information."
}