mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00005038.json

{
  "document_metadata": {
    "page_number": "9",
    "document_number": "334",
    "date": "08/13/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page 9 of 10\n\nno other theory of relevance (including that the materials are exculpatory or otherwise relate to the criminal charges at issue), and on this independent basis, the requests fail.\n\nRequest 8 seeks \"all\" photographs, diaries, journals, or other documentary evidence obtained from \"any\" person who has accused Maxwell. The request, another fishing expedition, is plainly unjustified under the Nixon test. The first problem relates to specificity. As above, the words \"all\" and \"any\" do not \"evince specificity.\" United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, 2021). Here, Maxwell does not attempt to narrow the request and instead seeks all materials obtained from any person who has accused Maxwell—at any point, without any limitations. Nixon requires greater specificity. See Nixon, 418 U.S. at 698–70. In addition, the requests fail because Maxwell has not established the relevance of all of those materials. Under Rule 17(c), the moving party must show that all of the requested material is relevant. Cf. United States v. Pena, No. 15-CR-551 (AJN), 2016 WL 8735699, at *2 (S.D.N.Y. Feb. 12, 2016). Clearly, the request seeks materials related to people who are not referenced in the Indictment. Maxwell has not made any kind of showing why those materials are relevant to the criminal charges she faces in this case. Thus, the request is improper.\n\nRequest 9 seeks the same evidence as the third request in the proposed subpoena to Subpoena Recipient-2. For the reasons discussed above, that request fails.\n\nFinally, Request 10 seeks EVCP materials. As discussed above, the only plausible theory of relevance for those materials is impeachment, and as such Maxwell has not established the relevance of those materials for purposes of the Nixon analysis.\n\nIn sum, none of the requests contained in these two subpoenas satisfy the Nixon factors. As a result, the requests are DENIED in full.\n\n9\nDOJ-OGR-00005038",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page 9 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "no other theory of relevance (including that the materials are exculpatory or otherwise relate to the criminal charges at issue), and on this independent basis, the requests fail.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Request 8 seeks \"all\" photographs, diaries, journals, or other documentary evidence obtained from \"any\" person who has accused Maxwell. The request, another fishing expedition, is plainly unjustified under the Nixon test. The first problem relates to specificity. As above, the words \"all\" and \"any\" do not \"evince specificity.\" United States v. Tagliaferro, No. 19-CR-472 (PAC), 2021 WL 980004, at *3 (S.D.N.Y. Mar. 16, 2021). Here, Maxwell does not attempt to narrow the request and instead seeks all materials obtained from any person who has accused Maxwell—at any point, without any limitations. Nixon requires greater specificity. See Nixon, 418 U.S. at 698–70. In addition, the requests fail because Maxwell has not established the relevance of all of those materials. Under Rule 17(c), the moving party must show that all of the requested material is relevant. Cf. United States v. Pena, No. 15-CR-551 (AJN), 2016 WL 8735699, at *2 (S.D.N.Y. Feb. 12, 2016). Clearly, the request seeks materials related to people who are not referenced in the Indictment. Maxwell has not made any kind of showing why those materials are relevant to the criminal charges she faces in this case. Thus, the request is improper.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Request 9 seeks the same evidence as the third request in the proposed subpoena to Subpoena Recipient-2. For the reasons discussed above, that request fails.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, Request 10 seeks EVCP materials. As discussed above, the only plausible theory of relevance for those materials is impeachment, and as such Maxwell has not established the relevance of those materials for purposes of the Nixon analysis.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In sum, none of the requests contained in these two subpoenas satisfy the Nixon factors. As a result, the requests are DENIED in full.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "9",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005038",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Nixon",
      "Tagliaferro",
      "Pena"
    ],
    "organizations": [
      "DOJ"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "08/13/21",
      "Mar. 16, 2021",
      "Feb. 12, 2016"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 334",
      "19-CR-472",
      "15-CR-551",
      "DOJ-OGR-00005038"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 9 of 10."
}