mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00004167.json

{
  "document_metadata": {
    "page_number": "32 of 34",
    "document_number": "285",
    "date": "05/20/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 285 Filed 05/20/21 Page 32 of 34\nThe government of course does not suggest that any of its agents, such as AUSA , would be willing to provide an affidavit to Maxwell or otherwise speak with defense counsel absent compulsion from this Court. Indeed, the government conspicuously did not attach to its Response any affidavits about its interactions with Boies Schiller.\nIt's plain, therefore, that this Court should hold an evidentiary hearing and effectuate Maxwell's constitutional right to compulsory process because that is the only way to get to the truth.22\nConclusion\nFor these reasons, as well as those given in the Motion, this Court should: (1) suppress all evidence the government obtained from Boies Schiller and any other evidence derived therefrom; or (2) suppress the April and July 2016 depositions and all evidence derived therefrom; and (3) dismiss Counts Five and Six. Maxwell requests an evidentiary hearing on this Motion.\nDated: March 15, 2021\n22 If this Court concludes an affidavit is required before it holds a hearing, Maxwell requests leave, as she did in her Motion, to attempt to obtain such an affidavit. But if, as is likely, none of the participants—e.g., AUSA , AUSA , Boies, Edwards, Skinner, Pottinger—voluntarily provides an affidavit, Maxwell invokes her constitutional right to compulsory process and this Court's authority to compel testimony in support of her defense. U.S. CONST. amend. VI.",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 285 Filed 05/20/21 Page 32 of 34",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The government of course does not suggest that any of its agents, such as AUSA , would be willing to provide an affidavit to Maxwell or otherwise speak with defense counsel absent compulsion from this Court. Indeed, the government conspicuously did not attach to its Response any affidavits about its interactions with Boies Schiller.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "It's plain, therefore, that this Court should hold an evidentiary hearing and effectuate Maxwell's constitutional right to compulsory process because that is the only way to get to the truth.22",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Conclusion",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "For these reasons, as well as those given in the Motion, this Court should: (1) suppress all evidence the government obtained from Boies Schiller and any other evidence derived therefrom; or (2) suppress the April and July 2016 depositions and all evidence derived therefrom; and (3) dismiss Counts Five and Six. Maxwell requests an evidentiary hearing on this Motion.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dated: March 15, 2021",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "22 If this Court concludes an affidavit is required before it holds a hearing, Maxwell requests leave, as she did in her Motion, to attempt to obtain such an affidavit. But if, as is likely, none of the participants—e.g., AUSA , AUSA , Boies, Edwards, Skinner, Pottinger—voluntarily provides an affidavit, Maxwell invokes her constitutional right to compulsory process and this Court's authority to compel testimony in support of her defense. U.S. CONST. amend. VI.",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "AUSA",
      "Boies",
      "Edwards",
      "Skinner",
      "Pottinger"
    ],
    "organizations": [
      "Boies Schiller"
    ],
    "locations": [],
    "dates": [
      "March 15, 2021",
      "April 2016",
      "July 2016",
      "05/20/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 285"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Maxwell. The text is mostly printed, with some redacted names. There are no visible stamps or handwritten notes."
}