{
  "document_metadata": {
    "page_number": "12",
    "document_number": "138",
    "date": "02/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 12 of 26\n\nI. Prejudice to Ms. Maxwell.\n\nAs a threshold observation, the government has failed to provide discovery adequate to fully investigate the extent of the prejudice to Ms. Maxwell. We have not been provided with:\n\n- The names of the Accusers;\n- The dates of birth of the Accusers;\n- The specific location of any overt act;\n- The date of any overt act;\n- Any witness statements; or\n- Any supposed corroboration of any allegation in the Indictment.\n\nLike the preindictment delay, the delay in timely providing discovery is tactical and prejudicial to Ms. Maxwell. Despite repeated requests, the government refuses to produce any evidence. Without knowing the who, what, when, and why of these allegations, the task of identifying dead and missing witnesses, percipient witness, travel records, phone records, or temporally relevant documents is challenging and limited by the vagueness of the claims. For example, the government produced part of its voluminous 2006 investigative case file concerning these issues. The names of the alleged witnesses, the agents who conducted the interviews and the agents who conducted the investigation are, however, redacted. Ms. Maxwell has no ability to conclusively identify these individuals much less interview them and therefore cannot represent to the Court whether they are alive, remember anything, or have useful evidence. By withholding this information, the government is purposefully preventing Ms. Maxwell from fully litigating this issue and presenting a defense.\n\nWhat we know, so far, however, will be sufficient to establish prejudice. Potential defense witnesses are dead, missing, otherwise unavailable, or unable to recall key events clearly. In contrast, the government will profit from the dimmed memories of witnesses with:\n\n7\n\nDOJ-OGR-00002515",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 12 of 26",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "I. Prejudice to Ms. Maxwell.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "As a threshold observation, the government has failed to provide discovery adequate to fully investigate the extent of the prejudice to Ms. Maxwell. We have not been provided with:\n\n- The names of the Accusers;\n- The dates of birth of the Accusers;\n- The specific location of any overt act;\n- The date of any overt act;\n- Any witness statements; or\n- Any supposed corroboration of any allegation in the Indictment.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Like the preindictment delay, the delay in timely providing discovery is tactical and prejudicial to Ms. Maxwell. Despite repeated requests, the government refuses to produce any evidence. Without knowing the who, what, when, and why of these allegations, the task of identifying dead and missing witnesses, percipient witness, travel records, phone records, or temporally relevant documents is challenging and limited by the vagueness of the claims. For example, the government produced part of its voluminous 2006 investigative case file concerning these issues. The names of the alleged witnesses, the agents who conducted the interviews and the agents who conducted the investigation are, however, redacted. Ms. Maxwell has no ability to conclusively identify these individuals much less interview them and therefore cannot represent to the Court whether they are alive, remember anything, or have useful evidence. By withholding this information, the government is purposefully preventing Ms. Maxwell from fully litigating this issue and presenting a defense.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "What we know, so far, however, will be sufficient to establish prejudice. Potential defense witnesses are dead, missing, otherwise unavailable, or unable to recall key events clearly. In contrast, the government will profit from the dimmed memories of witnesses with:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "7",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002515",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "Court",
      "government"
    ],
    "locations": [],
    "dates": [
      "02/04/21",
      "2006"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 138",
      "DOJ-OGR-00002515"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 12 of 26."
}