{
  "document_metadata": {
    "page_number": "8",
    "document_number": "287",
    "date": "05/20/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 287 Filed 05/20/21 Page 8 of 16\n\nThese new allegations—which expand the nature and scope of the charged conspiracies—are exactly the type of “surprise” revelations that a bill of particulars is designed to protect against. The Indictment makes no mention of these allegations, nor is there any information in the discovery indicating that they would be part of the government’s case. The government therefore cannot argue, as it does in its opposition, that the information provided in the Indictment and the discovery produced to date are sufficient for Ms. Maxwell to understand the nature of the charges against her, especially when only a small fraction of the discovery pertains to the time period charged in the Indictment. (Opp. 179-81). “The Government [does] not fulfill its obligation merely by providing mountains of documents to defense counsel” if the discovery does not identify the alleged criminal conduct.” Bortnovsky, 820 F.2d at 575; see also United States v. Luna, No. 3:05-CR-58 (SRU), 2006 WL 1668006, at *2 (D. Conn. May 17, 2006) (“[W]hen faced with ‘mountains’ of discovery or ‘massive disclosures,’ a defendant may still be unable to prepare for trial and prevent surprise.”).\n\nNor can the government take shelter in the fact that it has now disclosed these allegations. The government only made this disclosure because of Ms. Maxwell’s Surplusage Motion. Had she not made that motion, Ms. Maxwell would not have known about these allegations until she received Jencks Act disclosures a few weeks before trial, which would not have given her sufficient time to investigate 25-year-old allegations of _______________.\nIt also raises the question of whether Accuser-1 and Accuser-2 have alleged _______________ that are not included in the Indictment, but which the government plans to introduce at trial. Without a bill of particulars specifying the approximate dates, locations, and people involved in the alleged incidents of sexual abuse that the government plans to prove at trial, Ms.\n\n5\nDOJ-OGR-00004235",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 287 Filed 05/20/21 Page 8 of 16",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "These new allegations—which expand the nature and scope of the charged conspiracies—are exactly the type of “surprise” revelations that a bill of particulars is designed to protect against. The Indictment makes no mention of these allegations, nor is there any information in the discovery indicating that they would be part of the government’s case. The government therefore cannot argue, as it does in its opposition, that the information provided in the Indictment and the discovery produced to date are sufficient for Ms. Maxwell to understand the nature of the charges against her, especially when only a small fraction of the discovery pertains to the time period charged in the Indictment. (Opp. 179-81). “The Government [does] not fulfill its obligation merely by providing mountains of documents to defense counsel” if the discovery does not identify the alleged criminal conduct.” Bortnovsky, 820 F.2d at 575; see also United States v. Luna, No. 3:05-CR-58 (SRU), 2006 WL 1668006, at *2 (D. Conn. May 17, 2006) (“[W]hen faced with ‘mountains’ of discovery or ‘massive disclosures,’ a defendant may still be unable to prepare for trial and prevent surprise.”).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Nor can the government take shelter in the fact that it has now disclosed these allegations. The government only made this disclosure because of Ms. Maxwell’s Surplusage Motion. Had she not made that motion, Ms. Maxwell would not have known about these allegations until she received Jencks Act disclosures a few weeks before trial, which would not have given her sufficient time to investigate 25-year-old allegations of _______________.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "It also raises the question of whether Accuser-1 and Accuser-2 have alleged _______________ that are not included in the Indictment, but which the government plans to introduce at trial. Without a bill of particulars specifying the approximate dates, locations, and people involved in the alleged incidents of sexual abuse that the government plans to prove at trial, Ms.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004235",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Accuser-1",
      "Accuser-2"
    ],
    "organizations": [],
    "locations": [
      "D. Conn."
    ],
    "dates": [
      "05/20/21",
      "May 17, 2006"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 287",
      "3:05-CR-58 (SRU)",
      "2006 WL 1668006",
      "DOJ-OGR-00004235"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. There are two redacted sections in the text."
}