{
  "document_metadata": {
    "page_number": "214",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 214 of 239\n\nGovernment has reviewed the full report and confirmed that there is nothing exculpatory contained therein. To the contrary, the report inculpates the defendant. Accordingly, the defendant is not entitled to its immediate disclosure. The Government will produce an unredacted version of this document together with all other witness statements in advance of trial.67\n\nFourth, the defense requests production of pages from a personal diary that is in the custody of a civilian third party and is not in the custody or control of the Government. (Def. Mot. 10 at 10). Leaving aside the fact that the defense cites no authority for the proposition that the Government has an obligation to obtain the personal papers of a third party, see United States v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019) (“The Government’s ‘Brady obligations extend only to materials within prosecutors’ possession, custody or control or, in appropriate cases, that of the Department of Justice, perhaps another part of the Executive Branch, or a comparable state authority involved in the federal prosecution.’” (quoting United States v. Blaszczak, 308 F. Supp. 3d 736, 742 (S.D.N.Y. 2018))), the Government has already represented that it has asked the third party at issue about the materials the defendant purports to seek and that no such materials exist. In particular, to the extent the defense is concerned with whether there are diary entries from the spring of 1996, the Government has already indicated in response to the defendant’s second bail motion that it is aware of none. (See Dkt. No. 100 at 11 n.2 (“Because this victim stopped writing in her journal about a month after that first meeting with Epstein, there are no entries regarding the subsequent trip she took months later to visit Epstein, during which she met the defendant. This victim provided the Government with copies of her journal entries relating to Epstein and informed the Government that the remaining entries are personal in nature and have nothing to do with the Government that the remaining entries are personal in nature and have nothing to do with\n\n67 As is the case with the other redacted document referenced in this motion, the redacted copy defense counsel attached as Exhibit D was recovered during the execution of a search warrant for one of Epstein’s devices and was produced to defense counsel in the form in which it was recovered from the device.\n\n187\nDOJ-OGR-00003148",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 214 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Government has reviewed the full report and confirmed that there is nothing exculpatory contained therein. To the contrary, the report inculpates the defendant. Accordingly, the defendant is not entitled to its immediate disclosure. The Government will produce an unredacted version of this document together with all other witness statements in advance of trial.67",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Fourth, the defense requests production of pages from a personal diary that is in the custody of a civilian third party and is not in the custody or control of the Government. (Def. Mot. 10 at 10). Leaving aside the fact that the defense cites no authority for the proposition that the Government has an obligation to obtain the personal papers of a third party, see United States v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019) (“The Government’s ‘Brady obligations extend only to materials within prosecutors’ possession, custody or control or, in appropriate cases, that of the Department of Justice, perhaps another part of the Executive Branch, or a comparable state authority involved in the federal prosecution.’” (quoting United States v. Blaszczak, 308 F. Supp. 3d 736, 742 (S.D.N.Y. 2018))), the Government has already represented that it has asked the third party at issue about the materials the defendant purports to seek and that no such materials exist. In particular, to the extent the defense is concerned with whether there are diary entries from the spring of 1996, the Government has already indicated in response to the defendant’s second bail motion that it is aware of none. (See Dkt. No. 100 at 11 n.2 (“Because this victim stopped writing in her journal about a month after that first meeting with Epstein, there are no entries regarding the subsequent trip she took months later to visit Epstein, during which she met the defendant. This victim provided the Government with copies of her journal entries relating to Epstein and informed the Government that the remaining entries are personal in nature and have nothing to do with the Government that the remaining entries are personal in nature and have nothing to do with",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "67 As is the case with the other redacted document referenced in this motion, the redacted copy defense counsel attached as Exhibit D was recovered during the execution of a search warrant for one of Epstein’s devices and was produced to defense counsel in the form in which it was recovered from the device.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "187",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003148",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein"
    ],
    "organizations": [
      "Department of Justice"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "04/16/21",
      "1996"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "Dkt. No. 100",
      "DOJ-OGR-00003148"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with some footnote text. There are no visible stamps or handwritten annotations. The document is likely a scanned or digital version of the original filing."
}