{
  "document_metadata": {
    "page_number": "11",
    "document_number": "549-1",
    "date": "12/17/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 549-1 Filed 12/17/21 Page 11 of 24 23\nLB1TMAX1\n1 is the relevant basis for the jury's determination of guilt or\n2 innocence. Why and when the government conducted the\n3 investigation is not relevant. If the defense believes the\n4 government has a legally improper motive for prosecuting\n5 Ms. Maxwell or somehow fabricating evidence or suborning\n6 perjury or the like, the Second Circuit has made clear that the\n7 proper remedy is to file a motion for the Court to consider.\n8 See, Regan, 103 F.3d 1082. Absent that, the law is clear that\n9 for purposes of the jury, \"the government is not on trial.\"\n10 United States v. Knox, 687 F.App'x 51, (2d Cir. 2017).\n11 Moreover, evidence of motive would be highly\n12 prejudicial. For the reasons I explained a moment ago, it\n13 would confuse jurors as to the proper standard of guilt to be\n14 applied in the case. Indeed, the defense's outlined evidence\n15 of improper motives is strongly suggestive of jury\n16 nullification because it suggests a vindictive or political\n17 prosecution which is rightly a matter reserved to the Court.\n18 Calling witnesses to testify to the government's\n19 motive would substantially expand the scope of trial, rely\n20 likely on hearsay and other inadmissible evidence. So what\n21 motivated a particular investigative step or charging decision\n22 of course doesn't have a black or white answer, and the defense\n23 would have one story and the government another, neither of\n24 which would assist of the jury in deciding Ms. Maxwell's guilt\n25 or innocence of the charges here based on of the government's\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00008405",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 549-1 Filed 12/17/21 Page 11 of 24 23",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LB1TMAX1\n1 is the relevant basis for the jury's determination of guilt or\n2 innocence. Why and when the government conducted the\n3 investigation is not relevant. If the defense believes the\n4 government has a legally improper motive for prosecuting\n5 Ms. Maxwell or somehow fabricating evidence or suborning\n6 perjury or the like, the Second Circuit has made clear that the\n7 proper remedy is to file a motion for the Court to consider.\n8 See, Regan, 103 F.3d 1082. Absent that, the law is clear that\n9 for purposes of the jury, \"the government is not on trial.\"\n10 United States v. Knox, 687 F.App'x 51, (2d Cir. 2017).\n11 Moreover, evidence of motive would be highly\n12 prejudicial. For the reasons I explained a moment ago, it\n13 would confuse jurors as to the proper standard of guilt to be\n14 applied in the case. Indeed, the defense's outlined evidence\n15 of improper motives is strongly suggestive of jury\n16 nullification because it suggests a vindictive or political\n17 prosecution which is rightly a matter reserved to the Court.\n18 Calling witnesses to testify to the government's\n19 motive would substantially expand the scope of trial, rely\n20 likely on hearsay and other inadmissible evidence. So what\n21 motivated a particular investigative step or charging decision\n22 of course doesn't have a black or white answer, and the defense\n23 would have one story and the government another, neither of\n24 which would assist of the jury in deciding Ms. Maxwell's guilt\n25 or innocence of the charges here based on of the government's",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008405",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "Second Circuit",
      "Court",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/17/21",
      "2017"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "549-1",
      "DOJ-OGR-00008405"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. The text is printed and there are no visible handwritten notes or stamps. The document is from a court case involving Ms. Maxwell."
}