mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00004957.json

{
  "document_metadata": {
    "page_number": "3",
    "document_number": "314",
    "date": "07/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 314 Filed 07/12/21 Page 3 of 7\nPage 3\nlawyers was making outrageously false statements to the press.2 The prosecution responded: \"Spencer Kuvin does not represent any of the witnesses the Government expects to call at trial in this case. Because this individual does not represent any witnesses in this case,\" the local rules did not apply to him and there was no \"need to raise this issue with the Court.\"\n\nII. Even if the local rules somehow applied to undersigned counsel, the Op-Ed did not violate the local rule.\nEven if the local rule applies to a lawyer who does not currently represent a party or a witness and has never appeared in the trial court, the opinion piece here did not violate the rule.\nFirst, there is no risk of danger or prejudice to the upcoming trial because the Op-Ed raised the same argument - that the Cosby decision applied to Ms. Maxwell's case - that was filed in public pleadings that were quoted by the press. No confidential information was disclosed.3 Ms. Maxwell's trial lawyers made the very same argument in a public pleading that was quoted by the press. (Dkt. No. 310). In that public pleading, Ms. Maxwell's lawyers argue:\nThe Pennsylvania Supreme Court held that DA Castor's promise was enforceable and that DA Ferman's prosecution of Mr. Cosby ten years later on the same charges violated his Due Process rights. (Id. at 78-79). As a result, the Court vacated Mr. Cosby's conviction. (Id. at 79). In so holding, the Court noted the following:\nInteractions between a prosecutor and a criminal defendant, including circumstances where the latter seeks enforcement of some promise or assurance made by the former, are not immune from the dictates of due process and fundamental fairness.\n(Id. at 55).\nThe same principle applies to Ms. Maxwell's case. As in Cosby, the government is trying to renege on its agreement and prosecute Ms. Maxwell over 25 years later for the exact same offenses for which she was granted immunity in the NPA. Indeed, the principle applies even more strongly in Ms. Maxwell's case because the NPA was a formal\n\n2 Emma Parry, Will She Survive?, (May 6, 2021), https://www.thesun.co.uk/news/14875477/ghislain-maxwell-plea-deal-same-fate-as-epstein/\n3 See Gentile, 501 U.S. at 1074 (explaining that the risk of influencing a potential jury exists for trial lawyer because they \"have special access to information through discovery and client communications\" that others do not have).\nDOJ-OGR-00004957",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 314 Filed 07/12/21 Page 3 of 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "lawyers was making outrageously false statements to the press.2 The prosecution responded: \"Spencer Kuvin does not represent any of the witnesses the Government expects to call at trial in this case. Because this individual does not represent any witnesses in this case,\" the local rules did not apply to him and there was no \"need to raise this issue with the Court.\"\n\nII. Even if the local rules somehow applied to undersigned counsel, the Op-Ed did not violate the local rule.\nEven if the local rule applies to a lawyer who does not currently represent a party or a witness and has never appeared in the trial court, the opinion piece here did not violate the rule.\nFirst, there is no risk of danger or prejudice to the upcoming trial because the Op-Ed raised the same argument - that the Cosby decision applied to Ms. Maxwell's case - that was filed in public pleadings that were quoted by the press. No confidential information was disclosed.3 Ms. Maxwell's trial lawyers made the very same argument in a public pleading that was quoted by the press. (Dkt. No. 310). In that public pleading, Ms. Maxwell's lawyers argue:\nThe Pennsylvania Supreme Court held that DA Castor's promise was enforceable and that DA Ferman's prosecution of Mr. Cosby ten years later on the same charges violated his Due Process rights. (Id. at 78-79). As a result, the Court vacated Mr. Cosby's conviction. (Id. at 79). In so holding, the Court noted the following:\nInteractions between a prosecutor and a criminal defendant, including circumstances where the latter seeks enforcement of some promise or assurance made by the former, are not immune from the dictates of due process and fundamental fairness.\n(Id. at 55).\nThe same principle applies to Ms. Maxwell's case. As in Cosby, the government is trying to renege on its agreement and prosecute Ms. Maxwell over 25 years later for the exact same offenses for which she was granted immunity in the NPA. Indeed, the principle applies even more strongly in Ms. Maxwell's case because the NPA was a formal",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "2 Emma Parry, Will She Survive?, (May 6, 2021), https://www.thesun.co.uk/news/14875477/ghislain-maxwell-plea-deal-same-fate-as-epstein/",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "3 See Gentile, 501 U.S. at 1074 (explaining that the risk of influencing a potential jury exists for trial lawyer because they \"have special access to information through discovery and client communications\" that others do not have).",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004957",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Spencer Kuvin",
      "Ms. Maxwell",
      "DA Castor",
      "Mr. Cosby",
      "DA Ferman",
      "Emma Parry",
      "Gentile"
    ],
    "organizations": [
      "Pennsylvania Supreme Court",
      "Government"
    ],
    "locations": [],
    "dates": [
      "May 6, 2021",
      "07/12/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 314",
      "Dkt. No. 310",
      "501 U.S.",
      "DOJ-OGR-00004957"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell. The text is mostly printed, with some footnotes and a header/footer. There are no visible stamps or handwritten text."
}