mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00005227.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "345",
    "date": "October 14, 2021",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 345 Filed 10/14/21 Page 2 of 3\nThe Honorable Alison J. Nathan\nOctober 14, 2021\nPage 2\n\nMs. Maxwell's counsel conferred with the government about the timing for filing a motion under Rule 412. The government seeks to have the motion briefed before jury selection begins.\n\nImplicit in the language of Rule 412(c)(1)(B) is authority for the Court to permit a defendant to file a motion closer to trial than 14 days, for good cause. But contrary to the government's suggestion, the Rule does not contemplate a deadline more than 14 days before trial.1\n\nIn any event, Ms. Maxwell should not be required to file her Rule 412 motion any time before November 15, since it was just three days ago (October 11) that the government disclosed its 3500 material, including more than 8,000 pages of testifying witness disclosures. It will require significant time and resources to review and investigate this material and to identify any potentially admissible Rule 412 evidence.\n\nIt was also just three days ago that the government alerted defense counsel to its anticipated Rule 404(b) witnesses. Rule 412's procedures apply not just to alleged victims named in the indictment but to any alleged victim in a case involving sexual misconduct, including alleged 404(b) victims. Fed. R. Evid. 412, Advisory Committee Notes, 1994 Amendments (\"Rule 412 extends to 'pattern' witnesses in both criminal and civil cases about other instances of sexual misconduct by the person accused is otherwise admissible.\")\n\nFinally, Ms. Maxwell (who is in custody) was only provided a copy of the government's disclosures earlier today in the late morning. Until Ms. Maxwell is able to review the material,\n\n1 See Fed. R. Evid. 412, Advisory Committee Notes, 1994 Amendments, Subdivision (c) (\"The requirement of a motion before trial is continued in the amended rule, as is the provision that a late motion may be permitted for good cause shown.\" (emphasis added)).\n\nDOJ-OGR-00005227",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 345 Filed 10/14/21 Page 2 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nOctober 14, 2021\nPage 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell's counsel conferred with the government about the timing for filing a motion under Rule 412. The government seeks to have the motion briefed before jury selection begins.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Implicit in the language of Rule 412(c)(1)(B) is authority for the Court to permit a defendant to file a motion closer to trial than 14 days, for good cause. But contrary to the government's suggestion, the Rule does not contemplate a deadline more than 14 days before trial.1",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In any event, Ms. Maxwell should not be required to file her Rule 412 motion any time before November 15, since it was just three days ago (October 11) that the government disclosed its 3500 material, including more than 8,000 pages of testifying witness disclosures. It will require significant time and resources to review and investigate this material and to identify any potentially admissible Rule 412 evidence.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "It was also just three days ago that the government alerted defense counsel to its anticipated Rule 404(b) witnesses. Rule 412's procedures apply not just to alleged victims named in the indictment but to any alleged victim in a case involving sexual misconduct, including alleged 404(b) victims. Fed. R. Evid. 412, Advisory Committee Notes, 1994 Amendments (\"Rule 412 extends to 'pattern' witnesses in both criminal and civil cases about other instances of sexual misconduct by the person accused is otherwise admissible.\")",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, Ms. Maxwell (who is in custody) was only provided a copy of the government's disclosures earlier today in the late morning. Until Ms. Maxwell is able to review the material,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 See Fed. R. Evid. 412, Advisory Committee Notes, 1994 Amendments, Subdivision (c) (\"The requirement of a motion before trial is continued in the amended rule, as is the provision that a late motion may be permitted for good cause shown.\" (emphasis added)).",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005227",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell"
    ],
    "organizations": [
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "October 14, 2021",
      "October 11",
      "November 15"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 345",
      "DOJ-OGR-00005227"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is well-formatted and printed, with no visible handwriting or stamps. The document includes references to specific court rules and procedures."
}