{
  "document_metadata": {
    "page_number": "9",
    "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 9 of 16\n\nMaxwell cannot effectively prepare her defense and will be at risk of further \"surprise\" allegations on the eve of trial. See Bortnovsky, 820 F.2d at 575 (bill of particulars necessary to prevent the government from proceeding \"furtively\").\n\nMoreover, as discussed more fully in the Surplusage Reply, these new allegations represent an impermissible attempt by the government to broaden the scope of the alleged conspiracies and bolster its thin case with testimony that is irrelevant to the charged crimes.\n\nAccordingly, a bill of particulars is not only necessary so that Ms. Maxwell can adequately prepare her defense, but also so that the government cannot use evidence that is outside the scope of the charged conspiracies to prove its case. See United States v. Hsia, 24 F. Supp. 2d 14, 33 (D.D.C. 1998) (ordering a bill of particulars \"as to the scope of the alleged conspiratorial agreement\" and whether and how certain allegations \"were within the scope of the conspiracy charged\").4\n\nII. The Court Should Grant Ms. Maxwell's Request for Accelerated Disclosure of the Government's Witness List, Jencks Act Material, Brady/Giglio Material, Rule 404(b) Material, and Co-Conspirator Statements.\n\nAs set forth in Ms. Maxwell's opening brief, her case presents special circumstances and unique investigative challenges that justify accelerated disclosure of the identities of the government's witnesses, their prior statements and impeachment material, any expected Rule 404(b) evidence, and any potential co-conspirator statements. (Dkt. 148 at 14-15). In response, the government does not attempt to rebut Ms. Maxwell's justifications for accelerated disclosure of these materials. Instead, it offers a formulaic argument that Ms. Maxwell's case is no different than other recent high-profile trials in this District, that she has not made a sufficient\n\n4 It is telling that these new allegations are surfacing for the first time in the government's opposition. Either the government just learned this information from Accuser-3 or it was already aware of this information, but decided not to present it to the grand jury - perhaps because there is nothing whatsoever in the discovery that corroborates these statements.\n\n6\n\nDOJ-OGR-00004236",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 287 Filed 05/20/21 Page 9 of 16",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Maxwell cannot effectively prepare her defense and will be at risk of further \"surprise\" allegations on the eve of trial. See Bortnovsky, 820 F.2d at 575 (bill of particulars necessary to prevent the government from proceeding \"furtively\").",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Moreover, as discussed more fully in the Surplusage Reply, these new allegations represent an impermissible attempt by the government to broaden the scope of the alleged conspiracies and bolster its thin case with testimony that is irrelevant to the charged crimes.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Accordingly, a bill of particulars is not only necessary so that Ms. Maxwell can adequately prepare her defense, but also so that the government cannot use evidence that is outside the scope of the charged conspiracies to prove its case. See United States v. Hsia, 24 F. Supp. 2d 14, 33 (D.D.C. 1998) (ordering a bill of particulars \"as to the scope of the alleged conspiratorial agreement\" and whether and how certain allegations \"were within the scope of the conspiracy charged\").4",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "II. The Court Should Grant Ms. Maxwell's Request for Accelerated Disclosure of the Government's Witness List, Jencks Act Material, Brady/Giglio Material, Rule 404(b) Material, and Co-Conspirator Statements.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As set forth in Ms. Maxwell's opening brief, her case presents special circumstances and unique investigative challenges that justify accelerated disclosure of the identities of the government's witnesses, their prior statements and impeachment material, any expected Rule 404(b) evidence, and any potential co-conspirator statements. (Dkt. 148 at 14-15). In response, the government does not attempt to rebut Ms. Maxwell's justifications for accelerated disclosure of these materials. Instead, it offers a formulaic argument that Ms. Maxwell's case is no different than other recent high-profile trials in this District, that she has not made a sufficient",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "4 It is telling that these new allegations are surfacing for the first time in the government's opposition. Either the government just learned this information from Accuser-3 or it was already aware of this information, but decided not to present it to the grand jury - perhaps because there is nothing whatsoever in the discovery that corroborates these statements.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "6",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004236",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Bortnovsky",
      "Hsia",
      "Accuser-3"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [
      "District of Columbia"
    ],
    "dates": [
      "05/20/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 287",
      "Dkt. 148"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and easy to read."
}