{ "document_metadata": { "page_number": "15", "document_number": "224", "date": "04/20/21", "document_type": "court document", "has_handwriting": false, "has_stamps": false }, "full_text": "Case 1:20-cr-00330-PAE Document 224 Filed 04/20/21 Page 15 of 17 one or more of Ms. Maxwell's lawyers should become actual witnesses, a circumstance that would create a circus, not a fair trial. The truth of the matter is simple: the government included the Perjury Counts because it wants to call Ms. Maxwell a liar in front of the jury and because it wanted a way to introduce unrelated, but extremely prejudicial evidence of alleged sexual abuse through the back door. The simple, non-prejudicial, solution is to sever the Perjury Counts.7 CONCLUSION The Perjury Counts are improperly joined with the Mann Act Counts. A joint trial of these charges would deny Ms. Maxwell her right to a fair trial and her counsel. Accordingly, the Court should grant the request for a separate trial on the Perjury Counts. Dated: March 15, 2021 Respectfully submitted, s/ Jeffrey S. Pagliuca 7 Ms. Maxwell's Colorado Counsel would not participate as advocates in any trial of those charges but would testify as witnesses. 11 DOJ-OGR-00003912", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cr-00330-PAE Document 224 Filed 04/20/21 Page 15 of 17", "position": "header" }, { "type": "printed", "content": "one or more of Ms. Maxwell's lawyers should become actual witnesses, a circumstance that would create a circus, not a fair trial. The truth of the matter is simple: the government included the Perjury Counts because it wants to call Ms. Maxwell a liar in front of the jury and because it wanted a way to introduce unrelated, but extremely prejudicial evidence of alleged sexual abuse through the back door. The simple, non-prejudicial, solution is to sever the Perjury Counts.7", "position": "top" }, { "type": "printed", "content": "CONCLUSION", "position": "middle" }, { "type": "printed", "content": "The Perjury Counts are improperly joined with the Mann Act Counts. A joint trial of these charges would deny Ms. Maxwell her right to a fair trial and her counsel. Accordingly, the Court should grant the request for a separate trial on the Perjury Counts.", "position": "middle" }, { "type": "printed", "content": "Dated: March 15, 2021 Respectfully submitted, s/ Jeffrey S. Pagliuca", "position": "middle" }, { "type": "printed", "content": "7 Ms. Maxwell's Colorado Counsel would not participate as advocates in any trial of those charges but would testify as witnesses.", "position": "footer" }, { "type": "printed", "content": "11 DOJ-OGR-00003912", "position": "footer" } ], "entities": { "people": [ "Ms. Maxwell", "Jeffrey S. Pagliuca" ], "organizations": [], "locations": [ "Colorado" ], "dates": [ "March 15, 2021", "04/20/21" ], "reference_numbers": [ "1:20-cr-00330-PAE", "Document 224", "DOJ-OGR-00003912" ] }, "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is well-formatted and printed, with no visible handwriting or stamps. The document includes a signature block with the name 'Jeffrey S. Pagliuca'." }