{
  "document_metadata": {
    "page_number": "8",
    "document_number": "208-1",
    "date": "04/16/2021",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 208-1 Filed 04/16/21 Page 9 of 11 Case 1:20-cr-00330-PAE Document 298-1 Filed 04/21/21 Page 8 of 10 Jane Doe 4's claims would be \"duplicative\"; DE 298 at 1 n.1 (\"As promised . . . Jane Doe No. 3 and Jane Doe No. 4 do not seek to expand the number of pleadings filed in this case. If allowed to join this action, they would simply support the pleadings already being filed by Jane Doe No. 1 and Jane Doe No. 2.\"); DE 311 at 5 n.3 (\"[A]ll four victims (represented by the same legal counsel) intend to coordinate efforts and avoid duplicative pleadings.\"), 15 (Jane Doe 3 and Jane Doe 4 \"challenge the same secret agreement i.e., the NPA that the Government executed with Epstein and then concealed from the victims. This is made clear by the proposed amendment itself, in which all four victims simply allege the same general facts.\"). As the Does argue at length in their Rule 15 Motion, Jane Doe 1's original petition \"specifically allege[s] that the Government was violating not only her rights but the rights of other similarly-situated victims.\" (DE 311 at 2). The Court fails to see why the addition of \"other similarly-situated victims\" is now necessary to \"vindicate their rights as well.\" (DE 280 at 1). Of course, Jane Doe 3 and Jane Doe 4 can participate in this litigated effort to vindicate the rights of similarly situated victims — there is no requirement that the evidentiary proof submitted in this case come only from the named parties. Petitioners point out as much, noting that, regardless of whether this Court grants the Rule 15 Motion, \"they will call Jane Doe No. 3 as a witness at any trial.\" (DE 311 at 17 n.7). The necessary \"participation\" of Jane Doe 3 and Jane Doe 4 in this case can be satisfied by offering their properly supported and relevant, admissible, and non-cumulative testimony as needed, whether through testimony at trial (see DE 280 at 9) or affidavits submitted to support the relevancy of discovery requests4 (see 4 The non-party Jane Does clearly understand how to submit affidavits. (See DEs 291-1, 310-1). 8 GIUFFRE002851 DOJ-OGR-00003733",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 208-1 Filed 04/16/21 Page 9 of 11",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 298-1 Filed 04/21/21 Page 8 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Jane Doe 4's claims would be \"duplicative\"; DE 298 at 1 n.1 (\"As promised . . . Jane Doe No. 3 and Jane Doe No. 4 do not seek to expand the number of pleadings filed in this case. If allowed to join this action, they would simply support the pleadings already being filed by Jane Doe No. 1 and Jane Doe No. 2.\"); DE 311 at 5 n.3 (\"[A]ll four victims (represented by the same legal counsel) intend to coordinate efforts and avoid duplicative pleadings.\"), 15 (Jane Doe 3 and Jane Doe 4 \"challenge the same secret agreement i.e., the NPA that the Government executed with Epstein and then concealed from the victims. This is made clear by the proposed amendment itself, in which all four victims simply allege the same general facts.\"). As the Does argue at length in their Rule 15 Motion, Jane Doe 1's original petition \"specifically allege[s] that the Government was violating not only her rights but the rights of other similarly-situated victims.\" (DE 311 at 2). The Court fails to see why the addition of \"other similarly-situated victims\" is now necessary to \"vindicate their rights as well.\" (DE 280 at 1). Of course, Jane Doe 3 and Jane Doe 4 can participate in this litigated effort to vindicate the rights of similarly situated victims — there is no requirement that the evidentiary proof submitted in this case come only from the named parties. Petitioners point out as much, noting that, regardless of whether this Court grants the Rule 15 Motion, \"they will call Jane Doe No. 3 as a witness at any trial.\" (DE 311 at 17 n.7). The necessary \"participation\" of Jane Doe 3 and Jane Doe 4 in this case can be satisfied by offering their properly supported and relevant, admissible, and non-cumulative testimony as needed, whether through testimony at trial (see DE 280 at 9) or affidavits submitted to support the relevancy of discovery requests4 (see",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "4 The non-party Jane Does clearly understand how to submit affidavits. (See DEs 291-1, 310-1).",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "8",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "GIUFFRE002851",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003733",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jane Doe 1",
      "Jane Doe 2",
      "Jane Doe 3",
      "Jane Doe 4",
      "Epstein"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "04/16/2021",
      "04/21/2021"
    ],
    "reference_numbers": [
      "DE 298",
      "DE 311",
      "DE 280",
      "DE 291-1",
      "DE 310-1",
      "Case 1:20-cr-00330-PAE",
      "Document 208-1",
      "Document 298-1"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Jane Doe plaintiffs and the Government. The text discusses the plaintiffs' claims and the court's consideration of their Rule 15 Motion. The document is a printed court document with no handwritten text or stamps."
}