{
  "document_metadata": {
    "page_number": "5",
    "document_number": "224",
    "date": "04/20/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 224 Filed 04/20/21 Page 5 of 17\n\nCounts 5 and 6, \"the Perjury Counts,\" are improperly joined with Counts 1-4, the \"Mann Act Counts.\" For the reasons stated in Ms. Maxwell's original Motion and this Reply, the Court should sever the Perjury Counts and grant a separate trial on these charges.\n\nARGUMENT\n\nI. The Counts Are Improperly Joined.\n\nRule 8(a) of the Federal Rules of Criminal Procedure permits joinder of offenses only when they \"are of the same or similar character, or are based on the same act or transaction, or are connected with or constitute parts of a common scheme or plan.\" Fed. R. Crim. P. 8(a).\n\n\"Joinder is proper where the same evidence may be used to prove each count,\" United States v. Blakney, 941 F.2d 114, 116 (2d Cir.1991), or if the counts have a \"sufficient logical connection,\" United States v. Ruiz, 894 F.2d 501, 505 (2d Cir.1990).\n\nThe government's justifications for this ill-conceived superseding indictment (Indictment) demonstrate either fundamental misunderstandings or deliberate misrepresentations about the law and facts related to these allegations. The Perjury Counts allegedly occurred 22 years after the Mann Act Counts, during a defamation action concerning not whether Accuser-1 had sex with Jeffrey Epstein or Accusers-2 or 3 got a \"massage,\" but whether the fantastical statements made by Virginia Giuffre in 2015 were \"obvious lies.\" Those wild, now known to be false, claims included her assertion that she had been sexually trafficked to Alan Dershowitz among other famous celebrities and politicians, and her age at the time of the claimed trafficking.\n\nThe counts, collectively, are thus illegally and artificially connected and do not depend on the \"same evidence\" but rather would allow the introduction of improper, irrelevant, and prejudicial evidence not otherwise admissible.\n\n1\n\nDOJ-OGR-00003902",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 224 Filed 04/20/21 Page 5 of 17",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Counts 5 and 6, \"the Perjury Counts,\" are improperly joined with Counts 1-4, the \"Mann Act Counts.\" For the reasons stated in Ms. Maxwell's original Motion and this Reply, the Court should sever the Perjury Counts and grant a separate trial on these charges.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "ARGUMENT",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I. The Counts Are Improperly Joined.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Rule 8(a) of the Federal Rules of Criminal Procedure permits joinder of offenses only when they \"are of the same or similar character, or are based on the same act or transaction, or are connected with or constitute parts of a common scheme or plan.\" Fed. R. Crim. P. 8(a).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "\"Joinder is proper where the same evidence may be used to prove each count,\" United States v. Blakney, 941 F.2d 114, 116 (2d Cir.1991), or if the counts have a \"sufficient logical connection,\" United States v. Ruiz, 894 F.2d 501, 505 (2d Cir.1990).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government's justifications for this ill-conceived superseding indictment (Indictment) demonstrate either fundamental misunderstandings or deliberate misrepresentations about the law and facts related to these allegations. The Perjury Counts allegedly occurred 22 years after the Mann Act Counts, during a defamation action concerning not whether Accuser-1 had sex with Jeffrey Epstein or Accusers-2 or 3 got a \"massage,\" but whether the fantastical statements made by Virginia Giuffre in 2015 were \"obvious lies.\" Those wild, now known to be false, claims included her assertion that she had been sexually trafficked to Alan Dershowitz among other famous celebrities and politicians, and her age at the time of the claimed trafficking.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The counts, collectively, are thus illegally and artificially connected and do not depend on the \"same evidence\" but rather would allow the introduction of improper, irrelevant, and prejudicial evidence not otherwise admissible.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003902",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Jeffrey Epstein",
      "Virginia Giuffre",
      "Alan Dershowitz"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "04/20/21",
      "2015"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 224",
      "DOJ-OGR-00003902"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ghislaine Maxwell, with a clear and legible format. There are no visible redactions or damage to the document."
}