{
  "document_metadata": {
    "page_number": "13",
    "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 13 of 26\n\n(1) any inconsistency or vagary being excused by the passage of time and (2) any specific claim (to the extent any are forthcoming) being difficult to cross-examine because of the unavailability of documents or witnesses due to the passage of time.\n\nII. Dead Witnesses and The Lost Testimony.\n\nA. Jeffrey Epstein.\n\nMr. Epstein was found dead in his jail cell on August 10, 2019 while awaiting trial for conspiracy to commit sex trafficking in violation of 18 U.S.C.§ 371, and sex trafficking in violation of 18 U.S.C.§ 1591. The alleged range of Mr. Epstein's crimes was from 2002 to 2005.\n\nMr. Epstein is the individual with whom Ms. Maxwell is alleged to have conspired and aided in this case. See Indictment, ¶¶ 1, 2, 5, 9, 10, 11, and 16. Had Mr. Epstein not died, he would have testified in any trial against Ms. Maxwell that:\n\n- She did not knowingly aid or facilitate any sex trafficking or transportation of minors as alleged in the superseding indictment;\n- She was unaware of Mr. Epstein's activities that led to his indictment when the activities allegedly occurred;\n- Between 1994-1997, Ms. Maxwell was not involved in any sexual act or massage with any minor including Accusers 1-3 as alleged in the superseding indictment;\n- Consistent with written communications with Ms. Maxwell, Mr. Epstein would have testified that she , she should that the accusers were liars and were lying about any alleged criminal acts attributed to Ms. Maxwell; Ex. A.\n- He believed that attorneys for many alleged accusers attempted to extort money from him by fomenting meritless litigation against his former employees, including Ms. Maxwell.\n- As to Ms. Maxwell, And, she Ex. A.\n\nEpstein's testimony would have also authenticated and provided an evidentiary foundation for numerous documents central to the defense in this case including travel records,\n\n8\n\nDOJ-OGR-00002516",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 138 Filed 02/04/21 Page 13 of 26",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "(1) any inconsistency or vagary being excused by the passage of time and (2) any specific claim (to the extent any are forthcoming) being difficult to cross-examine because of the unavailability of documents or witnesses due to the passage of time.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "II. Dead Witnesses and The Lost Testimony.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "A. Jeffrey Epstein.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Mr. Epstein was found dead in his jail cell on August 10, 2019 while awaiting trial for conspiracy to commit sex trafficking in violation of 18 U.S.C.§ 371, and sex trafficking in violation of 18 U.S.C.§ 1591. The alleged range of Mr. Epstein's crimes was from 2002 to 2005.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Mr. Epstein is the individual with whom Ms. Maxwell is alleged to have conspired and aided in this case. See Indictment, ¶¶ 1, 2, 5, 9, 10, 11, and 16. Had Mr. Epstein not died, he would have testified in any trial against Ms. Maxwell that:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- She did not knowingly aid or facilitate any sex trafficking or transportation of minors as alleged in the superseding indictment;",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- She was unaware of Mr. Epstein's activities that led to his indictment when the activities allegedly occurred;",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- Between 1994-1997, Ms. Maxwell was not involved in any sexual act or massage with any minor including Accusers 1-3 as alleged in the superseding indictment;",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- Consistent with written communications with Ms. Maxwell, Mr. Epstein would have testified that she , she should that the accusers were liars and were lying about any alleged criminal acts attributed to Ms. Maxwell; Ex. A.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- He believed that attorneys for many alleged accusers attempted to extort money from him by fomenting meritless litigation against his former employees, including Ms. Maxwell.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- As to Ms. Maxwell, And, she Ex. A.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Epstein's testimony would have also authenticated and provided an evidentiary foundation for numerous documents central to the defense in this case including travel records,",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "8",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002516",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Ms. Maxwell"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "August 10, 2019",
      "2002",
      "2005",
      "1994",
      "1997",
      "02/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 138",
      "18 U.S.C.§ 371",
      "18 U.S.C.§ 1591",
      "DOJ-OGR-00002516"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ghislaine Maxwell, with references to Jeffrey Epstein and various legal statutes. The text is mostly printed, with some redacted sections."
}