mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00005117.json

{
  "document_metadata": {
    "page_number": "5",
    "document_number": "336-2",
    "date": "09/07/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 336-2 Filed 09/07/21 Page 5 of 21\n\nATTACHMENT A\n\nDEFINITIONS\n\n1. \"You\" or \"Your\" means Maria Farmer.\n\n2. \"Envelopes\" means the envelopes that You described in a podcast with Whitney Webb that aired on May 26, 2020 that You claimed \"still have the touch DNA and fingerprints on them\" of \"Jeffrey and Ghislaine\" and that you offered to the FBI but the FBI said \"we don't need it.\" https://soundcloud.com/user-414392239/271-epstein-victim-maria-farmer-speaks-part-2-the-last-american-vagabond-whitney-webb.\n\n3. \"Physical Evidence\" means the \"hundreds of photographs,\" \"old diaries,\" \"telephone books,\" \"Rolodexes,\" and \"mementos . . . collected from [Your] time with Epstein and Maxwell\" that You showed to Brad Edwards and/or Stanley Pottinger at Your Paducah, KY home in June 2016, as described in excerpts from Relentless Pursuit, attached as Exhibit A.\n\n4. \"Contingent Fee Agreement or Engagement Agreement\" means any writing describing the terms that You agreed to for legal services from any attorney as required by New York Rule of Professional Conduct 1.15 and 22 N.Y.C.R.R. Part 1215.\n\n5. \"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 B.\n\nINSTRUCTIONS\n\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 \"Envelopes\" and \"Physical Evidence,\" 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.\n\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.\n\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.\n\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.\n\n5. Any copy of a Document that is not identical shall be considered a separate document.\n\n6. All Documents shall be produced in the same order as they are kept or maintained by You in the ordinary course of business.\n\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-00005117",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 336-2 Filed 09/07/21 Page 5 of 21",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "ATTACHMENT A",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "DEFINITIONS",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1. \"You\" or \"Your\" means Maria Farmer.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "2. \"Envelopes\" means the envelopes that You described in a podcast with Whitney Webb that aired on May 26, 2020 that You claimed \"still have the touch DNA and fingerprints on them\" of \"Jeffrey and Ghislaine\" and that you offered to the FBI but the FBI said \"we don't need it.\" https://soundcloud.com/user-414392239/271-epstein-victim-maria-farmer-speaks-part-2-the-last-american-vagabond-whitney-webb.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "3. \"Physical Evidence\" means the \"hundreds of photographs,\" \"old diaries,\" \"telephone books,\" \"Rolodexes,\" and \"mementos . . . collected from [Your] time with Epstein and Maxwell\" that You showed to Brad Edwards and/or Stanley Pottinger at Your Paducah, KY home in June 2016, as described in excerpts from Relentless Pursuit, attached as Exhibit A.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "4. \"Contingent Fee Agreement or Engagement Agreement\" means any writing describing the terms that You agreed to for legal services from any attorney as required by New York Rule of Professional Conduct 1.15 and 22 N.Y.C.R.R. Part 1215.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "5. \"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 B.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "INSTRUCTIONS",
      "position": "header"
    },
    {
      "type": "printed",
      "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 \"Envelopes\" and \"Physical Evidence,\" 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.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "2. 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.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "3. 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.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "4. 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.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "5. Any copy of a Document that is not identical shall be considered a separate document.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "6. All Documents shall be produced in the same order as they are kept or maintained by You in the ordinary course of business.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "7. 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.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005117",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maria Farmer",
      "Whitney Webb",
      "Jeffrey",
      "Ghislaine",
      "Brad Edwards",
      "Stanley Pottinger",
      "Jeffrey S. Pagliuca",
      "Epstein",
      "Maxwell"
    ],
    "organizations": [
      "FBI"
    ],
    "locations": [
      "Paducah, KY",
      "New York"
    ],
    "dates": [
      "May 26, 2020",
      "June 2016",
      "April 1, 2021",
      "09/07/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 336-2",
      "DOJ-OGR-00005117"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Epstein and Maxwell. It contains definitions and instructions for the production of documents. The document is well-formatted and legible."
}