{
  "document_metadata": {
    "page_number": "21",
    "document_number": "285",
    "date": "05/20/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 285 Filed 05/20/21 Page 21 of 34\n\nmatters that were the subject of the Giuffre [defamation] Action,\" and having been misled by\nAUSA response, Judge McMahon erroneously (though blamelessly) concluded that\n\"[n]othing in this record suggests to me that Giuffre or Boies Schiller had anything\nto do with the Government's decision to convene a grand jury to look into the\nmatters that were the subject of the Giuffre Action. . . There is no evidence of\n\"collusion,\" to invoke a term of the moment, and it is quite clear that Boies Schiller\ndid not foment the Government's investigation.\nId. (emphasis added).\nFor her part, AUSA shared the very concern Judge McMahon later expressed to\nAUSA : that Boies Schiller was trying to instigate an investigation of Maxwell to\nleverage its position in the \"Giuffre Action.\" Mot. Ex. K, p 3. In the 2021 call, AUSA\nrecalled that the\npending CVRA civil case and other civil litigation . . . gave [her] some pause\nbecause she had other occasions where civil litigants have decided to report\nsomething to the USAO because they think it will help them in their civil case.\nAUSA even mentioned this concern to the Chief of the Criminal Division. Id. If AUSA\nand the Chief of the Criminal Division recognized what was going on, AUSA\ncan hardly feign ignorance. 19\nIf the government means to suggest that when Judge McMahon asked about any prior\ncontacts concerning \"the subject of your investigation,\" she was somehow confining her inquiry\nto the time period surrounding November 2018, see Resp. at 90-91, that too is an implausible\nreading of the transcript. If Judge McMahon meant \"subject\" to be a term of art (\"subject\" of the\ninvestigation as opposed to a \"target\" of the investigation), then the government should have\n19 Of course, if AUSA honestly did not understand Chief Judge McMahon's question,\nonce she issued her opinion there could no longer be any doubt. And at that point, AUSA\nwould have been duty-bound to correct the misimpression he had created. N.Y. Rules of Professional\nConduct, Rule 3.8, cmt. [6A] (\"Like other lawyers, prosecutors are subject to Rule 3.3, which requires a\nlawyer to take reasonable remedial measures to correct material evidence that the lawyer has offered\nwhen the lawyer comes to know of its falsity.\")\n16\nDOJ-OGR-00004156",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 285 Filed 05/20/21 Page 21 of 34",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "matters that were the subject of the Giuffre [defamation] Action,\" and having been misled by\nAUSA response, Judge McMahon erroneously (though blamelessly) concluded that\n\"[n]othing in this record suggests to me that Giuffre or Boies Schiller had anything\nto do with the Government's decision to convene a grand jury to look into the\nmatters that were the subject of the Giuffre Action. . . There is no evidence of\n\"collusion,\" to invoke a term of the moment, and it is quite clear that Boies Schiller\ndid not foment the Government's investigation.\nId. (emphasis added).\nFor her part, AUSA shared the very concern Judge McMahon later expressed to\nAUSA : that Boies Schiller was trying to instigate an investigation of Maxwell to\nleverage its position in the \"Giuffre Action.\" Mot. Ex. K, p 3. In the 2021 call, AUSA\nrecalled that the\npending CVRA civil case and other civil litigation . . . gave [her] some pause\nbecause she had other occasions where civil litigants have decided to report\nsomething to the USAO because they think it will help them in their civil case.\nAUSA even mentioned this concern to the Chief of the Criminal Division. Id. If AUSA\nand the Chief of the Criminal Division recognized what was going on, AUSA\ncan hardly feign ignorance. 19\nIf the government means to suggest that when Judge McMahon asked about any prior\ncontacts concerning \"the subject of your investigation,\" she was somehow confining her inquiry\nto the time period surrounding November 2018, see Resp. at 90-91, that too is an implausible\nreading of the transcript. If Judge McMahon meant \"subject\" to be a term of art (\"subject\" of the\ninvestigation as opposed to a \"target\" of the investigation), then the government should have",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "19 Of course, if AUSA honestly did not understand Chief Judge McMahon's question,\nonce she issued her opinion there could no longer be any doubt. And at that point, AUSA\nwould have been duty-bound to correct the misimpression he had created. N.Y. Rules of Professional\nConduct, Rule 3.8, cmt. [6A] (\"Like other lawyers, prosecutors are subject to Rule 3.3, which requires a\nlawyer to take reasonable remedial measures to correct material evidence that the lawyer has offered\nwhen the lawyer comes to know of its falsity.\")",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "16",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004156",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Giuffre",
      "Boies Schiller",
      "Judge McMahon",
      "Maxwell",
      "AUSA"
    ],
    "organizations": [
      "Boies Schiller",
      "USAO",
      "N.Y. Rules of Professional Conduct"
    ],
    "locations": [],
    "dates": [
      "05/20/21",
      "November 2018"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 285",
      "DOJ-OGR-00004156"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions of AUSA names. The text is mostly clear, but some parts are redacted."
}