mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00020781.json

{
  "document_metadata": {
    "page_number": "22",
    "document_number": "207",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 57, 02/28/2023, 3475900, Page163 of 208\nA-159\nCase 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 22 of 34\nAt a minimum, Maxwell's motion is premature. Courts typically evaluate whether a question was fundamentally ambiguous only after the development of a full factual record at trial. See, e.g., United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992). The evidence at trial may shed further light on whether the questions posed were objectively ambiguous in context or whether Maxwell subjectively understood them. In any event, the Court has closely considered each of the categories of questions that Maxwell argues are ambiguous. None of the alleged ambiguities Maxwell identifies rise to the level supporting dismissal of the charges. The context of the questions and answers, in conjunction with the Government's evidence, could lead a reasonable juror to conclude that the statements were perjurious. Truth and falsity are questions for the jury in all but the most extreme cases. The Court declines to usurp the jury's role on the limited pretrial record.\nB. A reasonable juror could conclude that Maxwell's statements were material\nMaxwell also argues that the perjury counts should be dismissed because none of the allegedly false statements were material to the defamation action. In a civil deposition, a statement is material if it has a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offense and thus ordinarily must be \"decided by the jury, not the court.\" Johnson v. United States, 520 U.S. 461, 465 (1997). Only the most extraordinary circumstances justify departure from this general rule. United States v. Forde, 740 F. Supp. 2d 406, 412 (S.D.N.Y. 2010) (citing Gaudin, 515 U.S. at 522–23).\nThe charged statements do not fall within this narrow exception. Maxwell contends that the questions did not relate to the sex trafficking and sexual abuse allegations at the center of the\n22\nDOJ-OGR-00020781",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 57, 02/28/2023, 3475900, Page163 of 208",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "A-159",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 22 of 34",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "At a minimum, Maxwell's motion is premature. Courts typically evaluate whether a question was fundamentally ambiguous only after the development of a full factual record at trial. See, e.g., United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992). The evidence at trial may shed further light on whether the questions posed were objectively ambiguous in context or whether Maxwell subjectively understood them. In any event, the Court has closely considered each of the categories of questions that Maxwell argues are ambiguous. None of the alleged ambiguities Maxwell identifies rise to the level supporting dismissal of the charges. The context of the questions and answers, in conjunction with the Government's evidence, could lead a reasonable juror to conclude that the statements were perjurious. Truth and falsity are questions for the jury in all but the most extreme cases. The Court declines to usurp the jury's role on the limited pretrial record.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "B. A reasonable juror could conclude that Maxwell's statements were material",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Maxwell also argues that the perjury counts should be dismissed because none of the allegedly false statements were material to the defamation action. In a civil deposition, a statement is material if it has a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offense and thus ordinarily must be \"decided by the jury, not the court.\" Johnson v. United States, 520 U.S. 461, 465 (1997). Only the most extraordinary circumstances justify departure from this general rule. United States v. Forde, 740 F. Supp. 2d 406, 412 (S.D.N.Y. 2010) (citing Gaudin, 515 U.S. at 522–23).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The charged statements do not fall within this narrow exception. Maxwell contends that the questions did not relate to the sex trafficking and sexual abuse allegations at the center of the",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "22",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00020781",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "Court",
      "Government"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "04/16/21",
      "02/28/2023"
    ],
    "reference_numbers": [
      "Case 22-1426",
      "Document 57",
      "Case 1:20-cr-00330-AJN",
      "Document 207",
      "DOJ-OGR-00020781"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Maxwell. The text discusses the materiality of Maxwell's statements in a defamation action and the court's decision not to dismiss the perjury counts."
}