mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008358.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "539",
    "date": "12/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 539 Filed 12/12/21 Page 2 of 3 Friday evening, the defense sent the Government a letter, attached as Exhibit A.2 The letter identifies thirty-five defense witnesses in alphabetical order, with no information about the order in which the witnesses would be called. The Government conferred with the defense about witness order yesterday and was informed that more information would be forthcoming. The Government has not received further information. Accordingly, the Government respectfully requests that the Court direct the defense to provide the Government, by 10:00 a.m. tomorrow, with its intended witnesses for Thursday and Friday of this week, and that the defense provide by Tuesday, December 14, its full intended witness order. Such an order would be consistent with the Government's disclosures: the Government provided the defense with its first five witnesses on November 24, five days before the start of trial, and a full ordered witness list on November 27, two days before the start of trial.3 2 The Government moves to file this exhibit under seal, consistent with the Court's prior ruling that the Government's witness list is identifying as to individuals who would testify under pseudonyms and individuals who have not yet testified. Tr. 1697. 3 The Government also provided its 3500 material on October 11, more than a month in advance of trial. The defendant's Rule 26.2 disclosures on Friday do not include material for many of the witnesses on her list. 2 DOJ-OGR-00008358",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 539 Filed 12/12/21 Page 2 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Friday evening, the defense sent the Government a letter, attached as Exhibit A.2 The letter identifies thirty-five defense witnesses in alphabetical order, with no information about the order in which the witnesses would be called. The Government conferred with the defense about witness order yesterday and was informed that more information would be forthcoming. The Government has not received further information. Accordingly, the Government respectfully requests that the Court direct the defense to provide the Government, by 10:00 a.m. tomorrow, with its intended witnesses for Thursday and Friday of this week, and that the defense provide by Tuesday, December 14, its full intended witness order. Such an order would be consistent with the Government's disclosures: the Government provided the defense with its first five witnesses on November 24, five days before the start of trial, and a full ordered witness list on November 27, two days before the start of trial.3",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "2 The Government moves to file this exhibit under seal, consistent with the Court's prior ruling that the Government's witness list is identifying as to individuals who would testify under pseudonyms and individuals who have not yet testified. Tr. 1697. 3 The Government also provided its 3500 material on October 11, more than a month in advance of trial. The defendant's Rule 26.2 disclosures on Friday do not include material for many of the witnesses on her list.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "page number"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008358",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [],
    "dates": [
      "November 24",
      "November 27",
      "October 11",
      "December 14",
      "Friday",
      "Thursday",
      "December 12, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 539",
      "3500",
      "Rule 26.2",
      "DOJ-OGR-00008358"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. It is a typed document with no handwritten text or stamps. The text is clear and legible."
}