{
  "document_metadata": {
    "page_number": "10",
    "document_number": "732",
    "date": "07/14/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 732 Filed 07/14/22 Page 10 of 25\nThe Honorable Alison J. Nathan\nNovember 22, 2021\nPage 10\ninterview on July 17, 2020. See 3500 material at 3505-067. Of course, this is the first time that\nMs. Maxwell's name surfaces. The economic incentives here are obvious—having settled her\nclaims in 2009, Accuser-4 needed new, more sensational information to get more money. The\nEVCP materials thus directly contradict the \"motive theory\" that will be advanced by the\nprosecution at trial—that Ms. Maxwell was the procurer of underaged women for Epstein. See\nMendez v. Artuz, 303 F.3d 411, 414 (2d Cir. 2002) (information relevant and \"exculpatory . . .\nwhen it directly contradicts the motive theory testified to by prosecution witnesses\").\nAs this Court has already ruled, Witness-3 cannot be called a \"victim\" of the charged\nconduct because she was not a minor. Even so, this Court ruled that \"some of the anticipated\ntestimony [from Witness-3] can serve as direct evidence, notwithstanding the fact that the\nalleged conduct as to [her] was not illegal for the purpose of the charges in this case.\" Ms.\nMaxwell and the jury have a right to know what Witness-3 said the EVCP about the alleged\nabuse she suffered, including how old she claimed to be when she was abused. If Witness-3\nmisrepresented her age to the EVCP, just as the government was misled by Witness-3 into\nportraying her as a minor to the grand jury and this Court, that fact bears directly on her\ncredibility. Again, it is no coincidence that, after receiving money from the fund, Witness-3 is\nnow telling the government that if asked at trial about \"specific dates when things occurred, the\nanswer might be she doesn't know.\" See 3500 material at 3513-059. Only when we see how\nWitness-3 described how old she was to the fund will we know the truth.\nIn last-ditch effort to preclude enforcement, the government says that Ms. Maxwell\n\"already has the information relevant this argument.\" Gov. Mot at 4. But even if that's true, that\nDOJ-OGR-00011433",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 732 Filed 07/14/22 Page 10 of 25",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nNovember 22, 2021\nPage 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "interview on July 17, 2020. See 3500 material at 3505-067. Of course, this is the first time that\nMs. Maxwell's name surfaces. The economic incentives here are obvious—having settled her\nclaims in 2009, Accuser-4 needed new, more sensational information to get more money. The\nEVCP materials thus directly contradict the \"motive theory\" that will be advanced by the\nprosecution at trial—that Ms. Maxwell was the procurer of underaged women for Epstein. See\nMendez v. Artuz, 303 F.3d 411, 414 (2d Cir. 2002) (information relevant and \"exculpatory . . .\nwhen it directly contradicts the motive theory testified to by prosecution witnesses\").",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "As this Court has already ruled, Witness-3 cannot be called a \"victim\" of the charged\nconduct because she was not a minor. Even so, this Court ruled that \"some of the anticipated\ntestimony [from Witness-3] can serve as direct evidence, notwithstanding the fact that the\nalleged conduct as to [her] was not illegal for the purpose of the charges in this case.\" Ms.\nMaxwell and the jury have a right to know what Witness-3 said the EVCP about the alleged\nabuse she suffered, including how old she claimed to be when she was abused. If Witness-3\nmisrepresented her age to the EVCP, just as the government was misled by Witness-3 into\nportraying her as a minor to the grand jury and this Court, that fact bears directly on her\ncredibility. Again, it is no coincidence that, after receiving money from the fund, Witness-3 is\nnow telling the government that if asked at trial about \"specific dates when things occurred, the\nanswer might be she doesn't know.\" See 3500 material at 3513-059. Only when we see how\nWitness-3 described how old she was to the fund will we know the truth.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "In last-ditch effort to preclude enforcement, the government says that Ms. Maxwell\n\"already has the information relevant this argument.\" Gov. Mot at 4. But even if that's true, that",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011433",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell",
      "Epstein",
      "Witness-3",
      "Accuser-4"
    ],
    "organizations": [
      "EVCP"
    ],
    "locations": [],
    "dates": [
      "July 17, 2020",
      "November 22, 2021",
      "2009",
      "07/14/22"
    ],
    "reference_numbers": [
      "3500 material at 3505-067",
      "303 F.3d 411, 414 (2d Cir. 2002)",
      "3500 material at 3513-059",
      "Case 1:20-cr-00330-PAE",
      "Document 732"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ghislaine Maxwell. The text discusses the credibility of Witness-3 and the relevance of certain evidence to the case. The document is well-formatted and free of significant damage or redactions."
}