{
  "document_metadata": {
    "page_number": "21",
    "document_number": "53",
    "date": "09/03/19",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 53 Filed 09/03/19 Page 21 of 86 21 J8RsEPS1 reasons, your Honor. One is the timing of Mr. Epstein's demise. It was on August 10. On August 12, a bail pending appeal motion was being filed in the Second Circuit. On August 12 or 13, the United States Attorneys were going to respond to our request for the preservation and production of documents that would have facilitated and furthered our efforts to demonstrate communications between the Southern District of Florida, the Northern District of Georgia, which was standing in the shoes of the Southern District of Florida main justice and the Southern District. In other words, we were beginning the process discharging our responsibilities. There had been no new evidence that Mr. Epstein had committed any offense against a minor after 2005. The subject matter of the New York prosecution was squarely within the heartland of the Florida NPA. We had a significant motion to dismiss. This was not a futile, you know, defeatist attitude. Third, we had all the discovery motions that your Honor had scheduled. So the timing for a pretrial detainee to commit suicide on August 10, when his bail pending appeal motion is being filed on August 12, strikes us as implausible. Second, we had an independent doctor who was present at the autopsy which occurred on August 11. On August 11, the city medical examiner's findings were inconclusive. We are SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000659",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 53 Filed 09/03/19 Page 21 of 86 21",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "J8RsEPS1 reasons, your Honor. One is the timing of Mr. Epstein's demise. It was on August 10. On August 12, a bail pending appeal motion was being filed in the Second Circuit. On August 12 or 13, the United States Attorneys were going to respond to our request for the preservation and production of documents that would have facilitated and furthered our efforts to demonstrate communications between the Southern District of Florida, the Northern District of Georgia, which was standing in the shoes of the Southern District of Florida main justice and the Southern District. In other words, we were beginning the process discharging our responsibilities. There had been no new evidence that Mr. Epstein had committed any offense against a minor after 2005. The subject matter of the New York prosecution was squarely within the heartland of the Florida NPA. We had a significant motion to dismiss. This was not a futile, you know, defeatist attitude. Third, we had all the discovery motions that your Honor had scheduled. So the timing for a pretrial detainee to commit suicide on August 10, when his bail pending appeal motion is being filed on August 12, strikes us as implausible. Second, we had an independent doctor who was present at the autopsy which occurred on August 11. On August 11, the city medical examiner's findings were inconclusive. We are",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000659",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mr. Epstein"
    ],
    "organizations": [
      "United States Attorneys",
      "Southern District Reporters, P.C."
    ],
    "locations": [
      "Florida",
      "Georgia",
      "New York",
      "Second Circuit",
      "Southern District of Florida",
      "Northern District of Georgia"
    ],
    "dates": [
      "August 10",
      "August 11",
      "August 12",
      "August 13",
      "2005",
      "09/03/19"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "53",
      "DOJ-OGR-00000659"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or filing related to the case of Mr. Epstein. The text is printed and legible, with no visible handwriting or stamps. The document includes a reference number and a footer with the name and contact information of the reporting agency."
}