{
  "document_metadata": {
    "page_number": "7",
    "document_number": "389",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 389 Filed 10/29/21 Page 7 of 11\n\nSecond, any evidence of alleged false statements, whether it is introduced as direct evidence of the perjury counts or as evidence of a purported effort to \"conceal\" the other crimes charged in the superseding indictment, would substantially prejudice Ms. Maxwell and would jeopardize her right to a fair trial for the same reasons the Court identified in its severance ruling. Allowing the jury to consider evidence related to the perjury counts \"would introduce unrelated allegations of sexual abuse, which would potentially expose the jury to evidence that might otherwise not be admissible . . . [and] to a wider swath of information regarding civil litigation against Epstein that is remote from Maxwell's charged conduct.\" Id. at 24. This would present \"a significant risk that the jury will cumulate the evidence of the various crimes charged and find guilt when, if considered separately, it would not do so.\" Id. Further, allowing the introduction of this evidence would \"likely to require disqualification of at least one of Maxwell's attorneys from participating as an advocate on her behalf,\" which would \"implicate[] [Ms.] Maxwell's Sixth Amendment right to be represented by the counsel of her choice\" and would significantly prejudice her right to a fair trial. Id. at 24-25. Introducing evidence related to the perjury counts as evidence of alleged concealment, or for any purpose, would present these same problems and should not be allowed.\n\nThird, as the Court recognized in its prior ruling, fully litigating the perjury charges—which would be necessary if the government were allowed to introduce the allegedly false deposition statements to show concealment—would result in a distracting and time-intensive side-show at trial that will confuse the jury with legal and factual issues that are far afield from the \"narrower issues\" that pertain to the other charged offenses. Id. at 25-26. This would frustrate the goal of a fair and efficient trial on the remaining charges. Id. at 26. For the same reasons, whatever probative value (if any) this evidence may have related to the other charged",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 389 Filed 10/29/21 Page 7 of 11",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Second, any evidence of alleged false statements, whether it is introduced as direct evidence of the perjury counts or as evidence of a purported effort to \"conceal\" the other crimes charged in the superseding indictment, would substantially prejudice Ms. Maxwell and would jeopardize her right to a fair trial for the same reasons the Court identified in its severance ruling. Allowing the jury to consider evidence related to the perjury counts \"would introduce unrelated allegations of sexual abuse, which would potentially expose the jury to evidence that might otherwise not be admissible . . . [and] to a wider swath of information regarding civil litigation against Epstein that is remote from Maxwell's charged conduct.\" Id. at 24. This would present \"a significant risk that the jury will cumulate the evidence of the various crimes charged and find guilt when, if considered separately, it would not do so.\" Id. Further, allowing the introduction of this evidence would \"likely to require disqualification of at least one of Maxwell's attorneys from participating as an advocate on her behalf,\" which would \"implicate[] [Ms.] Maxwell's Sixth Amendment right to be represented by the counsel of her choice\" and would significantly prejudice her right to a fair trial. Id. at 24-25. Introducing evidence related to the perjury counts as evidence of alleged concealment, or for any purpose, would present these same problems and should not be allowed.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Third, as the Court recognized in its prior ruling, fully litigating the perjury charges—which would be necessary if the government were allowed to introduce the allegedly false deposition statements to show concealment—would result in a distracting and time-intensive side-show at trial that will confuse the jury with legal and factual issues that are far afield from the \"narrower issues\" that pertain to the other charged offenses. Id. at 25-26. This would frustrate the goal of a fair and efficient trial on the remaining charges. Id. at 26. For the same reasons, whatever probative value (if any) this evidence may have related to the other charged",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "4",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005708",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Epstein",
      "Ms. Maxwell"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "10/29/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 389",
      "DOJ-OGR-00005708"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text discusses the potential prejudice of introducing evidence related to perjury counts and the potential impact on the defendant's right to a fair trial. The document is well-formatted and free of significant damage or redactions."
}