mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00004731.json

{
  "document_metadata": {
    "page_number": "24 of 26",
    "document_number": "295",
    "date": "05/25/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 24 of 26\n\nGiven the information the defendant already has from the Indictment and discovery, any additional detail would essentially serve as early Jencks Act production. The discovery gives the defense ample information to assist in its investigation, and given the defense's apparent ability to understand who Minor Victim-4 is from the productions, (see, e.g., Def. Mot. at 3, 7-9, 24-25), there is no real concern that the defense will waste efforts conducting any such investigation before receiving Jencks Act material.7 Accordingly, and consistent with the Court's prior ruling on a similar issue in this case, the motion for a bill of particulars should be denied.\n\nVII. Minor Victim-4's Prior Statements Constitute Giglio and Jencks Act Material, Which Do Not Warrant Immediate Disclosure\n\nThe defendant moves for the immediate disclosure of any prior inconsistent statement made by Minor Victim-4. In other words, the defense seeks immediate production of impeachment material for this particular witness under Giglio. As the Government has already noted in prior briefing, it is aware of its disclosure obligations and intends to produce Giglio material for all of its witnesses, including Minor Victim-4, at least six weeks in advance of trial. Consistent with the practice in this District, the Court has previously concluded that such time is sufficient for the defense to prepare for trial and make use of any impeachment material. (See Apr. Op. at 30).\n\nThe Government agrees that any prior statement in which Minor Victim-4 discussed her interactions with Epstein, but omitted mention of the defendant, must be disclosed to the defense in advance of trial. Contrary to the defense's assertion, however, such prior statements are classic impeachment material that need only be produced sufficiently in advance of trial to permit the defense adequate time to make use of them. See United States v. Coppa, 267 F.3d 132, 144, 146\n\n7 Although Minor Victim-4's identity is clear from the discovery, and the defendant's motion makes clear that she strongly suspects Minor Victim-4's identity, there is no basis at this time to require the Government to turn over the names of its witnesses, including its victim-witnesses in advance of its Jencks Act production, which is customary in this District.\n\n20\nDOJ-OGR-00004731",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page 24 of 26",
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    {
      "type": "printed",
      "content": "Given the information the defendant already has from the Indictment and discovery, any additional detail would essentially serve as early Jencks Act production. The discovery gives the defense ample information to assist in its investigation, and given the defense's apparent ability to understand who Minor Victim-4 is from the productions, (see, e.g., Def. Mot. at 3, 7-9, 24-25), there is no real concern that the defense will waste efforts conducting any such investigation before receiving Jencks Act material.7 Accordingly, and consistent with the Court's prior ruling on a similar issue in this case, the motion for a bill of particulars should be denied.",
      "position": "top"
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    {
      "type": "printed",
      "content": "VII. Minor Victim-4's Prior Statements Constitute Giglio and Jencks Act Material, Which Do Not Warrant Immediate Disclosure",
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    {
      "type": "printed",
      "content": "The defendant moves for the immediate disclosure of any prior inconsistent statement made by Minor Victim-4. In other words, the defense seeks immediate production of impeachment material for this particular witness under Giglio. As the Government has already noted in prior briefing, it is aware of its disclosure obligations and intends to produce Giglio material for all of its witnesses, including Minor Victim-4, at least six weeks in advance of trial. Consistent with the practice in this District, the Court has previously concluded that such time is sufficient for the defense to prepare for trial and make use of any impeachment material. (See Apr. Op. at 30).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government agrees that any prior statement in which Minor Victim-4 discussed her interactions with Epstein, but omitted mention of the defendant, must be disclosed to the defense in advance of trial. Contrary to the defense's assertion, however, such prior statements are classic impeachment material that need only be produced sufficiently in advance of trial to permit the defense adequate time to make use of them. See United States v. Coppa, 267 F.3d 132, 144, 146",
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    {
      "type": "printed",
      "content": "7 Although Minor Victim-4's identity is clear from the discovery, and the defendant's motion makes clear that she strongly suspects Minor Victim-4's identity, there is no basis at this time to require the Government to turn over the names of its witnesses, including its victim-witnesses in advance of its Jencks Act production, which is customary in this District.",
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    {
      "type": "printed",
      "content": "20",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00004731",
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  ],
  "entities": {
    "people": [
      "Minor Victim-4",
      "Epstein"
    ],
    "organizations": [
      "Government",
      "Court",
      "District",
      "Defense"
    ],
    "locations": [],
    "dates": [
      "05/25/21"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 295",
      "DOJ-OGR-00004731"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 24 of 26."
}