{
  "document_metadata": {
    "page_number": "7",
    "document_number": "518",
    "date": "November 30, 2021",
    "document_type": "court document",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 518 Filed 11/30/21 Page 7 of 8\nThe Honorable Alison J. Nathan\nNovember 30, 2021\nPage 7\n\nFinally, Rule 613, invoked by the government, has nothing to do with this issue. That rule addresses extrinsic evidence of prior inconsistent statements. The photograph Ms. Maxwell offered into evidence is not a prior inconsistent statement.\n***\nMs. Maxwell had no obligation (and has no obligation going forward) to disclose to the government any evidence (e.g., books, papers, documents, data, photographs, tangible objects, buildings or places) she does not intend to use during her “case-in-chief.” Fed. R. Crim. P. 16(b)(1)(A). Requiring such disclosure would violate the Fifth and Sixth Amendments. U.S. Const. amends. V, VI. This Court should reject the government’s contrary argument.\n\nDOJ-OGR-00008200",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 518 Filed 11/30/21 Page 7 of 8",
      "position": "header"
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    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nNovember 30, 2021\nPage 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Finally, Rule 613, invoked by the government, has nothing to do with this issue. That rule addresses extrinsic evidence of prior inconsistent statements. The photograph Ms. Maxwell offered into evidence is not a prior inconsistent statement.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "***",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell had no obligation (and has no obligation going forward) to disclose to the government any evidence (e.g., books, papers, documents, data, photographs, tangible objects, buildings or places) she does not intend to use during her “case-in-chief.” Fed. R. Crim. P. 16(b)(1)(A). Requiring such disclosure would violate the Fifth and Sixth Amendments. U.S. Const. amends. V, VI. This Court should reject the government’s contrary argument.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008200",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell"
    ],
    "organizations": [
      "government"
    ],
    "locations": [],
    "dates": [
      "November 30, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 518",
      "DOJ-OGR-00008200"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is well-formatted and legible. There are no visible redactions or damage."
}