{
  "document_metadata": {
    "page_number": "9",
    "document_number": "492",
    "date": "11/22/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 9 of 13\nPage 9\nthe Government anticipates that Minor Victim-3 will testify that\nFourth, evidence relating to Minor Victim-3 is evidence of the conspiracy's plan or modus operandi. \"[T]o establish a recurring modus operandi . . . it is enough that the characteristics relied upon are sufficiently idiosyncratic to permit a fair inference of a pattern's existence.\" United States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984). The pattern here is highly idiosyncratic. The defendant identified Minor Victim-3, befriended her, and invited her over.\nAll\nthis happened during the conspiracy, and at least one of the other Minor Victims will testify to each step in this pattern. \"[T]aken together, they establish the existence of a pattern.\" United States v. Carlton, 534 F.3d 97, 102 (2d Cir. 2008).\nThe defense argues that none of this is probative under Rule 404(b) because Minor Victim-3 was above the age of consent, so evidence relating to Minor Victim-3 is not probative of the defendant's \"intent of doing something illegal,\" such as a sex act with a minor. (11/01/21 Tr. 82:8-16). That, however, is just a way of repeating that all the elements of the offense are not satisfied as to Minor Victim-3. But evidence relating to Minor Victim-3 is probative of central questions about the defendant's knowledge, motive, intent, and role in the conspiracy. For instance, the Government expects that the defense may challenge (1) whether the defendant played a role in recruiting girls to give Epstein massages; (2) whether those girls were below or near the age of consent; (3) whether the defendant instructed those girls to give Epstein a massage, including by\nDOJ-OGR-00007426",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 492 Filed 11/22/21 Page 9 of 13",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "the Government anticipates that Minor Victim-3 will testify that",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Fourth, evidence relating to Minor Victim-3 is evidence of the conspiracy's plan or modus operandi. \"[T]o establish a recurring modus operandi . . . it is enough that the characteristics relied upon are sufficiently idiosyncratic to permit a fair inference of a pattern's existence.\" United States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984). The pattern here is highly idiosyncratic. The defendant identified Minor Victim-3, befriended her, and invited her over.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "All",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "this happened during the conspiracy, and at least one of the other Minor Victims will testify to each step in this pattern. \"[T]aken together, they establish the existence of a pattern.\" United States v. Carlton, 534 F.3d 97, 102 (2d Cir. 2008).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defense argues that none of this is probative under Rule 404(b) because Minor Victim-3 was above the age of consent, so evidence relating to Minor Victim-3 is not probative of the defendant's \"intent of doing something illegal,\" such as a sex act with a minor. (11/01/21 Tr. 82:8-16). That, however, is just a way of repeating that all the elements of the offense are not satisfied as to Minor Victim-3. But evidence relating to Minor Victim-3 is probative of central questions about the defendant's knowledge, motive, intent, and role in the conspiracy. For instance, the Government expects that the defense may challenge (1) whether the defendant played a role in recruiting girls to give Epstein massages; (2) whether those girls were below or near the age of consent; (3) whether the defendant instructed those girls to give Epstein a massage, including by",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00007426",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Minor Victim-3",
      "Epstein"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "11/22/21",
      "11/01/21"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 492",
      "DOJ-OGR-00007426"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving Jeffrey Epstein. The text is mostly printed, with some redacted sections. There are no visible stamps or handwritten notes."
}