mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00008959.json

{
  "document_metadata": {
    "page_number": "35 of 37",
    "document_number": "600",
    "date": "02/11/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 600 Filed 02/11/22 Page 35 of 37\n\n- Sally Markham - Ms. Markham was a property manager hired to help run Epstein's properties in the early 2000s. In its opening and closing statements, the government gave great emphasis to the household manual as evidence that Ms. Maxwell was the \"lady of the house\" who insisted on a \"culture of silence\" among Epstein's employees to hide the sexual abuse going on in his residences. Tr. 34, 2846-47. The defense believes that Ms. Markham could have testified that the household manual was not created by Ms. Maxwell, but by another individual known as \"the Countess,\" whom Epstein brought in to \"professionalize\" his staff.\n\n- Lynn Fontanilla - Ms. Fontanilla was the live-in housekeeper in Epstein's 71st Street townhouse throughout the relevant time period. The defense believes she could have testified that Ms. Maxwell rarely spent the night at the 71st Street townhouse and could rebut the government's assertion that Ms. Maxwell was always by Epstein's side.\n\nFor these reasons and the reasons set forth in Ms. Maxwell's previous submissions, the Court should vacate Ms. Maxwell's convictions as to all counts and dismiss the Indictment due to prejudicial pre-indictment delay.\n\nIV. The Court Should Enter a Judgment of Acquittal as to All Counts Because the Government Failed to Prove Each Element of the Charges Beyond a Reasonable Doubt.\n\nFollowing the close of the government's case-in-chief, Ms. Maxwell moved the Court under Rule 29 of the Federal Rules of Criminal Procedure to enter a judgment of acquittal as to all counts. Tr. 2266:4-2274:14. The Court denied the defendant's motion. Tr. 2274:16. Following the close of the defense case, Ms. Maxwell reasserted her Rule 29 motion for the reasons initially stated. Tr. 2736:8-9. Ms. Maxwell now reasserts that same motion and incorporates the arguments previously made to the Court.\n\nCONCLUSION\n\nFor the foregoing reasons, Ms. Maxwell respectfully requests that the Court, in the alternative, (1) vacate Ms. Maxwell's convictions on the Mann Act counts (Counts One through Four) and grant a new trial under Rule 33 because the convictions were based on a constructive amendment and/or variance from the allegations in the Indictment, (2) enter judgment on only\n\n30\n\nDOJ-OGR-00008959",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 600 Filed 02/11/22 Page 35 of 37",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "- Sally Markham - Ms. Markham was a property manager hired to help run Epstein's properties in the early 2000s. In its opening and closing statements, the government gave great emphasis to the household manual as evidence that Ms. Maxwell was the \"lady of the house\" who insisted on a \"culture of silence\" among Epstein's employees to hide the sexual abuse going on in his residences. Tr. 34, 2846-47. The defense believes that Ms. Markham could have testified that the household manual was not created by Ms. Maxwell, but by another individual known as \"the Countess,\" whom Epstein brought in to \"professionalize\" his staff.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "- Lynn Fontanilla - Ms. Fontanilla was the live-in housekeeper in Epstein's 71st Street townhouse throughout the relevant time period. The defense believes she could have testified that Ms. Maxwell rarely spent the night at the 71st Street townhouse and could rebut the government's assertion that Ms. Maxwell was always by Epstein's side.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "For these reasons and the reasons set forth in Ms. Maxwell's previous submissions, the Court should vacate Ms. Maxwell's convictions as to all counts and dismiss the Indictment due to prejudicial pre-indictment delay.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "IV. The Court Should Enter a Judgment of Acquittal as to All Counts Because the Government Failed to Prove Each Element of the Charges Beyond a Reasonable Doubt.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Following the close of the government's case-in-chief, Ms. Maxwell moved the Court under Rule 29 of the Federal Rules of Criminal Procedure to enter a judgment of acquittal as to all counts. Tr. 2266:4-2274:14. The Court denied the defendant's motion. Tr. 2274:16. Following the close of the defense case, Ms. Maxwell reasserted her Rule 29 motion for the reasons initially stated. Tr. 2736:8-9. Ms. Maxwell now reasserts that same motion and incorporates the arguments previously made to the Court.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "CONCLUSION",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "For the foregoing reasons, Ms. Maxwell respectfully requests that the Court, in the alternative, (1) vacate Ms. Maxwell's convictions on the Mann Act counts (Counts One through Four) and grant a new trial under Rule 33 because the convictions were based on a constructive amendment and/or variance from the allegations in the Indictment, (2) enter judgment on only",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "30",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008959",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Sally Markham",
      "Lynn Fontanilla",
      "Ms. Maxwell",
      "Epstein"
    ],
    "organizations": [
      "Court"
    ],
    "locations": [
      "71st Street"
    ],
    "dates": [
      "02/11/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 600",
      "Tr. 34",
      "Tr. 2846-47",
      "Tr. 2266:4-2274:14",
      "Tr. 2274:16",
      "Tr. 2736:8-9",
      "DOJ-OGR-00008959"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, with references to various trial transcripts and legal rules."
}