{
  "document_metadata": {
    "page_number": "4",
    "document_number": "239",
    "date": "04/23/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 239 Filed 04/23/21 Page 4 of 6\nPage 4\nthe FBI Florida File and the PBPD file, from which the Government has made Rule 16 productions, and which the Government is continuing to review for Giglio and Jencks Act material, (ii) the Palm Beach State Attorney's office file, from which the Government has made Rule 16 productions, and which the Government is continuing to review for Giglio and Jencks Act material; (iii) the file from the SDFL, discussed further below; (iv) the inbox for the primary line Assistant U.S. Attorney at SDFL responsible for that office's investigation of Jeffrey Epstein between 2005 and 2010 (\"Attorney-1\") that was previously gathered by OPR, discussed further below; and (v) certain potentially relevant materials, to the extent they existed, from a United States Attorney's Office in Georgia, which consist of a small amount of witness statements.\nWith respect to the SDFL file, based on an initial review,1 the Government has not identified any materials that would be subject to disclosure under Rule 16. This is unsurprising because discoverable materials such as subpoena returns and search warrant materials appear to have been maintained in the FBI Florida Office's file. Although the Government did identify materials that are broadly related to the NPA, the Government has not identified any items that would constitute Brady material. The Government is continuing to review the SDFL file for Giglio and Jencks Act material. And of course, to the extent the Government identifies potential Brady material or material discoverable under Rule 16 that is not duplicative of prior productions, it will promptly produce it.\n1 In the fall of 2020, SDFL agreed to provide SDNY with a copy of all of its files relating to Jeffrey Epstein so that SDNY could review those files for disclosures. Those files consist of 28 boxes, which contain material relating both to the investigation of Epstein and a civil lawsuit filed by victims challenging the NPA under the Crime Victims' Rights Act. The Government hired a vendor to scan the files in these boxes, but technical difficulties with that vendor prevented those scans from being loaded into a document review platform until several weeks ago. Before those scans were loaded into the document review platform, the Government conducted an initial review of the scans in their native form.\nDOJ-OGR-00003958",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 239 Filed 04/23/21 Page 4 of 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 4",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "the FBI Florida File and the PBPD file, from which the Government has made Rule 16 productions, and which the Government is continuing to review for Giglio and Jencks Act material, (ii) the Palm Beach State Attorney's office file, from which the Government has made Rule 16 productions, and which the Government is continuing to review for Giglio and Jencks Act material; (iii) the file from the SDFL, discussed further below; (iv) the inbox for the primary line Assistant U.S. Attorney at SDFL responsible for that office's investigation of Jeffrey Epstein between 2005 and 2010 (\"Attorney-1\") that was previously gathered by OPR, discussed further below; and (v) certain potentially relevant materials, to the extent they existed, from a United States Attorney's Office in Georgia, which consist of a small amount of witness statements.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "With respect to the SDFL file, based on an initial review,1 the Government has not identified any materials that would be subject to disclosure under Rule 16. This is unsurprising because discoverable materials such as subpoena returns and search warrant materials appear to have been maintained in the FBI Florida Office's file. Although the Government did identify materials that are broadly related to the NPA, the Government has not identified any items that would constitute Brady material. The Government is continuing to review the SDFL file for Giglio and Jencks Act material. And of course, to the extent the Government identifies potential Brady material or material discoverable under Rule 16 that is not duplicative of prior productions, it will promptly produce it.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "1 In the fall of 2020, SDFL agreed to provide SDNY with a copy of all of its files relating to Jeffrey Epstein so that SDNY could review those files for disclosures. Those files consist of 28 boxes, which contain material relating both to the investigation of Epstein and a civil lawsuit filed by victims challenging the NPA under the Crime Victims' Rights Act. The Government hired a vendor to scan the files in these boxes, but technical difficulties with that vendor prevented those scans from being loaded into a document review platform until several weeks ago. Before those scans were loaded into the document review platform, the Government conducted an initial review of the scans in their native form.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003958",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Attorney-1"
    ],
    "organizations": [
      "FBI",
      "PBPD",
      "SDFL",
      "SDNY",
      "OPR"
    ],
    "locations": [
      "Florida",
      "Palm Beach",
      "Georgia"
    ],
    "dates": [
      "04/23/21",
      "2005",
      "2010",
      "2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 239",
      "DOJ-OGR-00003958"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Jeffrey Epstein. The text is mostly printed, with a footnote providing additional context. There are no visible stamps or handwritten text."
}