{
  "document_metadata": {
    "page_number": "11",
    "document_number": "494",
    "date": "11/22/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 494 Filed 11/22/21 Page 11 of 12\n\nThe Honorable Alison J. Nathan\nNovember 11, 2021\nPage 11\n\nconsent. The defense proposes the following instruction, which is modeled on the proposed instruction for Accuser-3:\n\nYou have heard testimony from this witness about sexual activity between her and Jeffrey Epstein that occurred [choose all that apply: in Florida when she was above the age of 18; in the U.S. Virgin Islands when she was above the age of 18; in New York when she was above the age of 17; in New Mexico when she was above the age of 16; in the United Kingdom when she was above the age of 16].\n\nFor the purposes of your deliberations, I instruct you that at all times relevant to this case the legal age of consent for sexual activity [choose all that apply: in Florida was 18 years old; in the U.S. Virgin Islands was 18 years old; in New York was 17 years old; in New Mexico was 16 years old; in the United Kingdom was 16 years old].\n\nIf you find that the witness engaged in sexual activity after she was above the relevant age of consent, I instruct you that any such sexual activity was lawful and cannot be considered \"illegal\" or \"criminal\" or \"unlawful\" for purposes of the crimes charged in the indictment.\n\nIV. Accuser-3 Cannot Be Considered a \"Victim\" for Any Legal Purpose\n\nThe Court ruled at the November 10th hearing that Accuser-3 could not be considered a \"victim\" of the crimes charged in the S2 Indictment and that the government should not refer to her as a \"victim\" or a \"minor.\" Accordingly, there is no need for the defense to respond to the government's November 7th Letter.\n\nRespectfully submitted,\n\n/s/ Christian Everdell\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue, 21st Floor\n\n2049808.1\nDOJ-OGR-00007447",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 494 Filed 11/22/21 Page 11 of 12",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nNovember 11, 2021\nPage 11",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "consent. The defense proposes the following instruction, which is modeled on the proposed instruction for Accuser-3:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "You have heard testimony from this witness about sexual activity between her and Jeffrey Epstein that occurred [choose all that apply: in Florida when she was above the age of 18; in the U.S. Virgin Islands when she was above the age of 18; in New York when she was above the age of 17; in New Mexico when she was above the age of 16; in the United Kingdom when she was above the age of 16].",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "For the purposes of your deliberations, I instruct you that at all times relevant to this case the legal age of consent for sexual activity [choose all that apply: in Florida was 18 years old; in the U.S. Virgin Islands was 18 years old; in New York was 17 years old; in New Mexico was 16 years old; in the United Kingdom was 16 years old].",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "If you find that the witness engaged in sexual activity after she was above the relevant age of consent, I instruct you that any such sexual activity was lawful and cannot be considered \"illegal\" or \"criminal\" or \"unlawful\" for purposes of the crimes charged in the indictment.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "IV. Accuser-3 Cannot Be Considered a \"Victim\" for Any Legal Purpose",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The Court ruled at the November 10th hearing that Accuser-3 could not be considered a \"victim\" of the crimes charged in the S2 Indictment and that the government should not refer to her as a \"victim\" or a \"minor.\" Accordingly, there is no need for the defense to respond to the government's November 7th Letter.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,",
      "position": "body"
    },
    {
      "type": "signature",
      "content": "/s/ Christian Everdell",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "Christian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue, 21st Floor",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "2049808.1\nDOJ-OGR-00007447",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Jeffrey Epstein",
      "Christian Everdell",
      "Christian R. Everdell"
    ],
    "organizations": [
      "COHEN & GRESSER LLP"
    ],
    "locations": [
      "Florida",
      "U.S. Virgin Islands",
      "New York",
      "New Mexico",
      "United Kingdom"
    ],
    "dates": [
      "November 11, 2021",
      "November 10th",
      "November 7th",
      "11/22/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 494",
      "S2 Indictment",
      "2049808.1",
      "DOJ-OGR-00007447"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Jeffrey Epstein. The text is mostly printed, with a signature at the end. There are no visible stamps or handwritten annotations."
}