mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00019655.json

{
  "document_metadata": {
    "page_number": "9",
    "document_number": "94",
    "date": "10/08/2020",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 20-3061, Document 94, 10/08/2020, 2948481, Page9 of 23\n\nAns.Br. 18. But as Ms. Maxwell explained in her opening brief, if Judge Preska orders the deposition transcripts unsealed, the government will invoke Judge Preska's order as a shield against its improper conduct. Op.Br. 27-28, 30. The government will argue that it would have inevitably discovered Ms. Maxwell's deposition transcripts or that any improper conduct on its part was ultimately harmless. Op.Br. 30. Conspicuously, the government in the answer brief never denies that it will make such an argument. Ans.Br. 18 & n.4.\n\nThe government responds that if Ms. Maxwell “is concerned that unsealing will open up an inevitable discovery argument for the Government, she can explain to Judge Nathan when making a suppression motion how an unsealing decision would have been altered by revelation of criminal discovery materials to the unsealing court.” Ans.Br. 18. This is fanciful thinking.\n\nIf this Court affirms Judge Preska's decision unsealing the deposition material, Judge Nathan likely will not (cannot?) reject an inevitable discovery argument from the government. Judge Nathan is not going to second-guess Judge Preska's decision to unseal the deposition material if this Court affirms its release. This, of course, explains why the government has not moved to intervene in Giuffre v. Maxwell, No. 15-cv-7433 (S.D.N.Y.), to stay the unsealing process, or to oppose the unsealing of the deposition material. Because Judge Preska and the panel of this\n\n6\n\nDOJ-OGR-00019655",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 20-3061, Document 94, 10/08/2020, 2948481, Page9 of 23",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Ans.Br. 18. But as Ms. Maxwell explained in her opening brief, if Judge Preska orders the deposition transcripts unsealed, the government will invoke Judge Preska's order as a shield against its improper conduct. Op.Br. 27-28, 30. The government will argue that it would have inevitably discovered Ms. Maxwell's deposition transcripts or that any improper conduct on its part was ultimately harmless. Op.Br. 30. Conspicuously, the government in the answer brief never denies that it will make such an argument. Ans.Br. 18 & n.4.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "The government responds that if Ms. Maxwell “is concerned that unsealing will open up an inevitable discovery argument for the Government, she can explain to Judge Nathan when making a suppression motion how an unsealing decision would have been altered by revelation of criminal discovery materials to the unsealing court.” Ans.Br. 18. This is fanciful thinking.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "If this Court affirms Judge Preska's decision unsealing the deposition material, Judge Nathan likely will not (cannot?) reject an inevitable discovery argument from the government. Judge Nathan is not going to second-guess Judge Preska's decision to unseal the deposition material if this Court affirms its release. This, of course, explains why the government has not moved to intervene in Giuffre v. Maxwell, No. 15-cv-7433 (S.D.N.Y.), to stay the unsealing process, or to oppose the unsealing of the deposition material. Because Judge Preska and the panel of this",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "6",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00019655",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Judge Preska",
      "Judge Nathan"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "10/08/2020"
    ],
    "reference_numbers": [
      "Case 20-3061",
      "Document 94",
      "2948481",
      "No. 15-cv-7433",
      "DOJ-OGR-00019655"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case Giuffre v. Maxwell. The text is printed and there are no visible stamps or handwritten annotations. The document is page 9 of 23."
}