DOJ-OGR-00005057.json 6.6 KB

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  1. {
  2. "document_metadata": {
  3. "page_number": "5",
  4. "document_number": "336-1",
  5. "date": "09/07/21",
  6. "document_type": "Attachment A",
  7. "has_handwriting": false,
  8. "has_stamps": false
  9. },
  10. "full_text": "Case 1:20-cr-00330-PAE Document 336-1 Filed 09/07/21 Page 5 of 60\n\nATTACHMENT A\n\nDEFINITIONS\n1. \"You\" or \"Your\" means Annie Farmer.\n2. \"Journal\" means the spiral notebook depicted in Exhibit A to this Attachment A.\n3. \"Black Boots\" means the footwear depicted in Exhibit B to this Attachment A.\n4. \"Photographs\" means the original developed film photographs, any negatives reflecting these photographs, and any digital images of those photographs, all produced in the Annie Farmer v. Darren Indyke, et. al., Case No. 19-cv-10475-LGS (S.D.N.Y) depicted in Exhibit C to this Attachment A as AFARMER 10470, 11339, 11688-11694, 12106-12107, 537-558.\n5. \"Contingent Fee Agreement or Engagement Agreement\" means any writing describing the terms that You agreed to receive legal services as required by New York Rule of Professional Conduct 1.15 and 22 N.Y.C.R.R. Part 1215.\n6. \"EVCP Material\" refers to any submission to the Epstein Victim's Compensation Program made by You, any releases signed by You and/or the Epstein Victim's Compensation Program, and any compensation received by You. The EVCP is described in Exhibit D to this Attachment A.\n\nINSTRUCTIONS\n1. Production of documents and items requested herein shall be made no later than April 1, 2021, at 1:00 p.m. Except for the originals of the \"Journal\", \"Black Boots\" and \"Photographs,\" you may provide the records electronically by that date and time to Jeffrey S. Pagliuca or by such other method as agreed upon with counsel for the subpoenaing party.\n2. This Request calls for the production of all responsive Documents in Your possession, custody or control without regard to the physical location of such documents.\n3. If any Document was in your possession or control, but is no longer, state what disposition was made of said Document, the reason for the disposition, and the date of such disposition.\n4. In producing Documents, if the original of any Document cannot be located, a copy shall be produced in lieu thereof, and shall be legible and bound or stapled in the same manner as the original.\n5. Any copy of a Document that is not identical shall be considered a separate document.\n6. All Documents shall be produced in the same order as they are kept or maintained by You in the ordinary course of business.\n7. Responsive electronically stored information (ESI) shall be produced in its native form; that is, in the form in which the information was customarily created, used and stored by the native application employed by the producing party in the ordinary course of business.\n\nDOJ-OGR-00005057",
  11. "text_blocks": [
  12. {
  13. "type": "printed",
  14. "content": "Case 1:20-cr-00330-PAE Document 336-1 Filed 09/07/21 Page 5 of 60",
  15. "position": "header"
  16. },
  17. {
  18. "type": "printed",
  19. "content": "ATTACHMENT A",
  20. "position": "header"
  21. },
  22. {
  23. "type": "printed",
  24. "content": "DEFINITIONS",
  25. "position": "header"
  26. },
  27. {
  28. "type": "printed",
  29. "content": "1. \"You\" or \"Your\" means Annie Farmer.\n2. \"Journal\" means the spiral notebook depicted in Exhibit A to this Attachment A.\n3. \"Black Boots\" means the footwear depicted in Exhibit B to this Attachment A.\n4. \"Photographs\" means the original developed film photographs, any negatives reflecting these photographs, and any digital images of those photographs, all produced in the Annie Farmer v. Darren Indyke, et. al., Case No. 19-cv-10475-LGS (S.D.N.Y) depicted in Exhibit C to this Attachment A as AFARMER 10470, 11339, 11688-11694, 12106-12107, 537-558.\n5. \"Contingent Fee Agreement or Engagement Agreement\" means any writing describing the terms that You agreed to receive legal services as required by New York Rule of Professional Conduct 1.15 and 22 N.Y.C.R.R. Part 1215.\n6. \"EVCP Material\" refers to any submission to the Epstein Victim's Compensation Program made by You, any releases signed by You and/or the Epstein Victim's Compensation Program, and any compensation received by You. The EVCP is described in Exhibit D to this Attachment A.",
  30. "position": "body"
  31. },
  32. {
  33. "type": "printed",
  34. "content": "INSTRUCTIONS",
  35. "position": "header"
  36. },
  37. {
  38. "type": "printed",
  39. "content": "1. Production of documents and items requested herein shall be made no later than April 1, 2021, at 1:00 p.m. Except for the originals of the \"Journal\", \"Black Boots\" and \"Photographs,\" you may provide the records electronically by that date and time to Jeffrey S. Pagliuca or by such other method as agreed upon with counsel for the subpoenaing party.\n2. This Request calls for the production of all responsive Documents in Your possession, custody or control without regard to the physical location of such documents.\n3. If any Document was in your possession or control, but is no longer, state what disposition was made of said Document, the reason for the disposition, and the date of such disposition.\n4. In producing Documents, if the original of any Document cannot be located, a copy shall be produced in lieu thereof, and shall be legible and bound or stapled in the same manner as the original.\n5. Any copy of a Document that is not identical shall be considered a separate document.\n6. All Documents shall be produced in the same order as they are kept or maintained by You in the ordinary course of business.\n7. Responsive electronically stored information (ESI) shall be produced in its native form; that is, in the form in which the information was customarily created, used and stored by the native application employed by the producing party in the ordinary course of business.",
  40. "position": "body"
  41. },
  42. {
  43. "type": "printed",
  44. "content": "DOJ-OGR-00005057",
  45. "position": "footer"
  46. }
  47. ],
  48. "entities": {
  49. "people": [
  50. "Annie Farmer",
  51. "Darren Indyke",
  52. "Jeffrey S. Pagliuca"
  53. ],
  54. "organizations": [
  55. "Epstein Victim's Compensation Program"
  56. ],
  57. "locations": [
  58. "New York"
  59. ],
  60. "dates": [
  61. "April 1, 2021",
  62. "09/07/21"
  63. ],
  64. "reference_numbers": [
  65. "1:20-cr-00330-PAE",
  66. "336-1",
  67. "19-cv-10475-LGS",
  68. "AFARMER 10470",
  69. "11339",
  70. "11688-11694",
  71. "12106-12107",
  72. "537-558",
  73. "DOJ-OGR-00005057"
  74. ]
  75. },
  76. "additional_notes": "The document appears to be a formal legal attachment with definitions and instructions related to a court case. The text is clear and legible, with no visible redactions or damage."
  77. }