{
  "document_metadata": {
    "page_number": "14",
    "document_number": "453",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 14 of 52\n\nreference their status positions, and the government has no evidence that she was not already well-established friends of many years with both of the men. And even if she were trying to ingratiate herself to a friend, so what? It has no bearing on the \"recruitment\" or \"grooming\" of minor females to be sexually abused by Jeffrey Epstein, as the Indictment charges.\n\nThe government contends that these Emails reveal \"defendant's intent and motive,\" but their argument is defies logic. If Ms. Maxwell had an intent to arrange adult dates for adult men that were her friends, then that shows a lack of intent to go find underage females to be abused by Jeffrey Epstein. If her motive is to permit adult women to date her single friends, then it is not to pick up schoolgirls off the street to give \"sexual massages\" to Jeffrey Epstein. And if she already had access to other powerful and influential men who were in her life, she would not need her friendship or access to Jeffrey Epstein. The only way that these emails could evidence a \"motive and intent\" is by drawing the improper inference that Ms. Maxwell has a propensity to \"facilitate encounters between powerful men and women they would like.\" This is exactly the type of evidence forbidden by Rule 404(b). See United States v. Angelilli, 660 F.2d 23, 40-41 (2d Cir. 1981) (\"While we conclude that the custom and practice evidence was admissible for the purposes we have discussed, we agree with the defendants that Rule 404(b) barred its use to prove that the individual defendants acted in conformity with the custom and practice. ...\").\n\nEven if the Court overlooks the government's failure to provide notice, the Emails' absence of relevance to the charged conspiracy, and the government's failure to set forth a non-propensity ground for admissibility, the Emails should also be excluded under Rules 401 and 403, as they do not tend to make any fact of consequence more or less probable, and their probative value is substantially outweighed by the danger of unfair prejudice and confusing the issues. The government carefully avoids mentioning the identities of the \"men in a position of\n\n8\n\nDOJ-OGR-00006894",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 14 of 52",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "reference their status positions, and the government has no evidence that she was not already well-established friends of many years with both of the men. And even if she were trying to ingratiate herself to a friend, so what? It has no bearing on the \"recruitment\" or \"grooming\" of minor females to be sexually abused by Jeffrey Epstein, as the Indictment charges.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The government contends that these Emails reveal \"defendant's intent and motive,\" but their argument is defies logic. If Ms. Maxwell had an intent to arrange adult dates for adult men that were her friends, then that shows a lack of intent to go find underage females to be abused by Jeffrey Epstein. If her motive is to permit adult women to date her single friends, then it is not to pick up schoolgirls off the street to give \"sexual massages\" to Jeffrey Epstein. And if she already had access to other powerful and influential men who were in her life, she would not need her friendship or access to Jeffrey Epstein. The only way that these emails could evidence a \"motive and intent\" is by drawing the improper inference that Ms. Maxwell has a propensity to \"facilitate encounters between powerful men and women they would like.\" This is exactly the type of evidence forbidden by Rule 404(b). See United States v. Angelilli, 660 F.2d 23, 40-41 (2d Cir. 1981) (\"While we conclude that the custom and practice evidence was admissible for the purposes we have discussed, we agree with the defendants that Rule 404(b) barred its use to prove that the individual defendants acted in conformity with the custom and practice. ...\").",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Even if the Court overlooks the government's failure to provide notice, the Emails' absence of relevance to the charged conspiracy, and the government's failure to set forth a non-propensity ground for admissibility, the Emails should also be excluded under Rules 401 and 403, as they do not tend to make any fact of consequence more or less probable, and their probative value is substantially outweighed by the danger of unfair prejudice and confusing the issues. The government carefully avoids mentioning the identities of the \"men in a position of",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "8",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006894",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Ms. Maxwell"
    ],
    "organizations": [
      "United States"
    ],
    "locations": [],
    "dates": [
      "11/12/21",
      "1981"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 453",
      "DOJ-OGR-00006894"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, discussing the admissibility of certain emails as evidence. The text is printed and there are no visible stamps or handwritten notes."
}