mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003114.json

{
  "document_metadata": {
    "page_number": "180",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 180 of 239 asserts that the crimes charged in Counts One through Four require additional specificity without citing any authority in support of such a broad claim. (See Def. Mot. 12 at 2). In particular, the defendant suggests that the failure to identify each minor victim by name, the presence of a date range rather than specific dates, and the use of certain language that the defendant claims not to understand render Counts One through Four so deficient that they must be dismissed. Because the defendant cites no authority indicating that violations of 18 U.S.C. §§ 371, 2422, or 2423 fall into the rare exception to “the rule that ‘an indictment need do little more than to track the language of the statute charged,’” her motion should be denied. United States v. Murgio, 209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). First, the use of pseudonyms to refer to minor victims of the charged conduct does not warrant dismissal of the Indictment. See Stringer, 730 F.3d at 124 (affirming sufficiency of fraud indictment “[n]otwithstanding its failure to specify the names of persons whose identifying documents were used” in scheme where prosecution provided victims’ names in advance of trial). The identity of a victim is not required to be included on the face of a charging instrument, and the “lack of any identity or date of birth information of the alleged victims does not warrant dismissal” of charges alleging sexual abuse. United States v. Kidd, 386 F. Supp.3d 364, 369 (S.D.N.Y. 2019). The defendant cites no law to the contrary and has not identified a single indictment in this District that includes the full names of minor victims of sexual abuse. Indeed, it makes good sense that a charging instrument alleging sexual abuse of minors would not include the full names of minor victims, whose privacy Congress has emphasized should be protected. See 18 U.S.C. § 3509(d) (delineating privacy protections for child victims and witnesses). Judge Marrero’s decision in Kidd, which denied a motion to dismiss a sex trafficking charges in violation of 18 U.S.C. § 1591 where the indictment referred to victims by pseudonyms, 153 DOJ-OGR-00003114",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 180 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "asserts that the crimes charged in Counts One through Four require additional specificity without citing any authority in support of such a broad claim. (See Def. Mot. 12 at 2). In particular, the defendant suggests that the failure to identify each minor victim by name, the presence of a date range rather than specific dates, and the use of certain language that the defendant claims not to understand render Counts One through Four so deficient that they must be dismissed. Because the defendant cites no authority indicating that violations of 18 U.S.C. §§ 371, 2422, or 2423 fall into the rare exception to “the rule that ‘an indictment need do little more than to track the language of the statute charged,’” her motion should be denied. United States v. Murgio, 209 F. Supp. 3d 698, 716 (S.D.N.Y. 2016) (Nathan, J.) (quoting Stringer, 730 F.3d at 124). First, the use of pseudonyms to refer to minor victims of the charged conduct does not warrant dismissal of the Indictment. See Stringer, 730 F.3d at 124 (affirming sufficiency of fraud indictment “[n]otwithstanding its failure to specify the names of persons whose identifying documents were used” in scheme where prosecution provided victims’ names in advance of trial). The identity of a victim is not required to be included on the face of a charging instrument, and the “lack of any identity or date of birth information of the alleged victims does not warrant dismissal” of charges alleging sexual abuse. United States v. Kidd, 386 F. Supp.3d 364, 369 (S.D.N.Y. 2019). The defendant cites no law to the contrary and has not identified a single indictment in this District that includes the full names of minor victims of sexual abuse. Indeed, it makes good sense that a charging instrument alleging sexual abuse of minors would not include the full names of minor victims, whose privacy Congress has emphasized should be protected. See 18 U.S.C. § 3509(d) (delineating privacy protections for child victims and witnesses). Judge Marrero’s decision in Kidd, which denied a motion to dismiss a sex trafficking charges in violation of 18 U.S.C. § 1591 where the indictment referred to victims by pseudonyms,",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "153",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003114",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Murgio",
      "Nathan",
      "Stringer",
      "Kidd",
      "Marrero"
    ],
    "organizations": [
      "Congress"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "04/16/21",
      "2016",
      "2019"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "18 U.S.C. §§ 371",
      "18 U.S.C. § 2422",
      "18 U.S.C. § 2423",
      "18 U.S.C. § 3509(d)",
      "18 U.S.C. § 1591",
      "209 F. Supp. 3d 698",
      "730 F.3d at 124",
      "386 F. Supp.3d 364"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and legible."
}