mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00010558.json

{
  "document_metadata": {
    "page_number": "23",
    "document_number": "670",
    "date": "06/22/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 23 of 55\n\nemployees was unnecessary. The book is authentic, and the defendant offers no basis for concluding otherwise.2\n\nThe Court should reject the defendant's argument and make its determination regarding the final date of the conspiracy based on the language of the Indictment (which plainly encompasses all of 2004) and the trial testimony of Carolyn (who testified that the offense conduct ran past 2004). The 2004 Manual applies.\n\n3. The Court Should Apply the 2004 Manual\n\nThe defendant also claims that the \"goals of sentencing are not served\" by applying the 2004 Manual. (Def. Mem. 8 (capitalization removed)). Not so. The law plainly provides that the 2004 Manual applies here, and it would be unjust to provide a substantial break in the Sentencing Guidelines for a defendant who engaged in an extensive child exploitation scheme, especially when both Congress and the Sentencing Commission have since further increased the applicable penalties for these offenses.\n\nMoreover, the Court should not credit the defendant's claim that she broke away from Epstein in 2002, based on the testimony of a sole defense witness who said that the defendant had \"moved on\" in 2002. (Def. Mem. 9). To be clear, \"once it has been established that there existed a conspiracy of which the defendant was a member, [her] membership is presumed to continue unless and until the defendant proves that the conspiracy was terminated or that [she] took\n\n2 In any event, the Government will bring the message book to sentencing so that the Court may examine it if it deems such an assessment necessary. If the Court desires additional testimony in the record, a case agent would be prepared to testify at the sentencing hearing based on the FBI's investigation that this message book was seized by the Palm Beach Police Department along with the other three message books admitted at trial, and was transferred into the custody of the FBI, which has maintained it ever since. It is well established that hearsay is admissible at sentencing. See United States v. Martinez, 413 F.3d 239, 242 (2d Cir. 2005) (\"the right of confrontation does not apply to the sentencing context and does not prohibit the consideration of hearsay testimony in sentencing proceedings.\")\n\n21\nDOJ-OGR-00010558",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 23 of 55",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "employees was unnecessary. The book is authentic, and the defendant offers no basis for concluding otherwise.2",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Court should reject the defendant's argument and make its determination regarding the final date of the conspiracy based on the language of the Indictment (which plainly encompasses all of 2004) and the trial testimony of Carolyn (who testified that the offense conduct ran past 2004). The 2004 Manual applies.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "3. The Court Should Apply the 2004 Manual",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant also claims that the \"goals of sentencing are not served\" by applying the 2004 Manual. (Def. Mem. 8 (capitalization removed)). Not so. The law plainly provides that the 2004 Manual applies here, and it would be unjust to provide a substantial break in the Sentencing Guidelines for a defendant who engaged in an extensive child exploitation scheme, especially when both Congress and the Sentencing Commission have since further increased the applicable penalties for these offenses.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Moreover, the Court should not credit the defendant's claim that she broke away from Epstein in 2002, based on the testimony of a sole defense witness who said that the defendant had \"moved on\" in 2002. (Def. Mem. 9). To be clear, \"once it has been established that there existed a conspiracy of which the defendant was a member, [her] membership is presumed to continue unless and until the defendant proves that the conspiracy was terminated or that [she] took",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2 In any event, the Government will bring the message book to sentencing so that the Court may examine it if it deems such an assessment necessary. If the Court desires additional testimony in the record, a case agent would be prepared to testify at the sentencing hearing based on the FBI's investigation that this message book was seized by the Palm Beach Police Department along with the other three message books admitted at trial, and was transferred into the custody of the FBI, which has maintained it ever since. It is well established that hearsay is admissible at sentencing. See United States v. Martinez, 413 F.3d 239, 242 (2d Cir. 2005) (\"the right of confrontation does not apply to the sentencing context and does not prohibit the consideration of hearsay testimony in sentencing proceedings.\")",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "21",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010558",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Carolyn",
      "Epstein",
      "Martinez"
    ],
    "organizations": [
      "FBI",
      "Palm Beach Police Department",
      "Sentencing Commission",
      "Congress"
    ],
    "locations": [
      "Palm Beach"
    ],
    "dates": [
      "2002",
      "2004",
      "06/22/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 670",
      "413 F.3d 239",
      "DOJ-OGR-00010558"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}