mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008407.json

{
  "document_metadata": {
    "page_number": "13",
    "document_number": "549-1",
    "date": "12/17/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 549-1 Filed 12/17/21 Page 13 of 24 25 LB1TMAX1 New York. Similarly, no matter how a witness who has a settlement or financial incentive testifies, those benefits are not received under the NPA, so I don't see any theory of bias that would be relevant that the defense has articulated with respect to the NPA. Moreover, even if there were some relevance, it would be substantially outweighed by a significant risk of 403 prejudice from introducing the NPA. The jury would need to be instructed on what the non-prosecution agreement is, and would need to have its terms explained. In particular, NPA, of course, is controversial and complicated and has a complicated background. There's a risk of undue delay, juror confusion, and improper suggestions of sympathy or nullification made to the jury on the basis of the NPA. I will be clear, it's not clear to me the NPA could never be admitted, but the rationale now provided by the defense in its papers does not justify admission based on the balancing of 401 and 403 factors. Fourth guidance: The government's charging decisions are likely not relevant and therefore inadmissible. The government didn't indict Ms. Maxwell by the end of the Florida investigation, and the government didn't indict Ms. Maxwell when it indicted Jeffrey Epstein originally in New York. As the Second Circuit stated in White, charging decisions can be SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00008407",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 549-1 Filed 12/17/21 Page 13 of 24 25",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "LB1TMAX1 New York.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Similarly, no matter how a witness who has a settlement or financial incentive testifies, those benefits are not received under the NPA, so I don't see any theory of bias that would be relevant that the defense has articulated with respect to the NPA.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Moreover, even if there were some relevance, it would be substantially outweighed by a significant risk of 403 prejudice from introducing the NPA. The jury would need to be instructed on what the non-prosecution agreement is, and would need to have its terms explained. In particular, NPA, of course, is controversial and complicated and has a complicated background. There's a risk of undue delay, juror confusion, and improper suggestions of sympathy or nullification made to the jury on the basis of the NPA.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I will be clear, it's not clear to me the NPA could never be admitted, but the rationale now provided by the defense in its papers does not justify admission based on the balancing of 401 and 403 factors.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Fourth guidance: The government's charging decisions are likely not relevant and therefore inadmissible. The government didn't indict Ms. Maxwell by the end of the Florida investigation, and the government didn't indict Ms. Maxwell when it indicted Jeffrey Epstein originally in New York. As the Second Circuit stated in White, charging decisions can be",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008407",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Ms. Maxwell"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "New York",
      "Florida"
    ],
    "dates": [
      "12/17/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "549-1",
      "DOJ-OGR-00008407"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document related to a case involving Jeffrey Epstein and Ms. Maxwell. The text is typed and there are no visible handwritten notes or stamps."
}