mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011363.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "723",
    "date": "December 16, 2021",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 723 Filed 07/12/22 Page 1 of 13\nHaddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com\nDecember 16, 2021\nVIA Email\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,\nI write in response to the government's motion to preclude testimony from Eva Dubin, Michelle Healy, and Kelly Bovino.1 The government claims that testimony from Eva, Michelle, and Kelly is inadmissible because: (1) it does not contradict Jane's testimony; and (2) it is improper impeachment on a collateral matter. The government is wrong.\nBACKGROUND\nOn the stand, Jane alleged that several other women were involved in sexual conduct and group sexualized massages with her, Mr. Epstein, and Ms. Maxwell. These women included Eva, Michelle, and Kelly. TR. at 523-30. Although Jane has not always been consistent with the government about the involvement of these women, she testified that all these women were involved in or could \"confirm\" what happened in the group sexualized massages that are the\n1 The government also moved to preclude certain testimony from John Lopez. That part of the motion is moot because Ms. Maxwell will not call Mr. Lopez as a witness.\nDOJ-OGR-00011363",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 723 Filed 07/12/22 Page 1 of 13",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Haddon, Morgan and Foreman, P.C\nJeffrey S. Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364\nFX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "December 16, 2021",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "VIA Email\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "I write in response to the government's motion to preclude testimony from Eva Dubin, Michelle Healy, and Kelly Bovino.1 The government claims that testimony from Eva, Michelle, and Kelly is inadmissible because: (1) it does not contradict Jane's testimony; and (2) it is improper impeachment on a collateral matter. The government is wrong.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "BACKGROUND",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On the stand, Jane alleged that several other women were involved in sexual conduct and group sexualized massages with her, Mr. Epstein, and Ms. Maxwell. These women included Eva, Michelle, and Kelly. TR. at 523-30. Although Jane has not always been consistent with the government about the involvement of these women, she testified that all these women were involved in or could \"confirm\" what happened in the group sexualized massages that are the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 The government also moved to preclude certain testimony from John Lopez. That part of the motion is moot because Ms. Maxwell will not call Mr. Lopez as a witness.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011363",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey S. Pagliuca",
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Eva Dubin",
      "Michelle Healy",
      "Kelly Bovino",
      "Jane",
      "Mr. Epstein",
      "Ms. Maxwell",
      "John Lopez",
      "Mr. Lopez"
    ],
    "organizations": [
      "Haddon, Morgan and Foreman, P.C",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "Denver",
      "Colorado",
      "New York"
    ],
    "dates": [
      "December 16, 2021",
      "07/12/22"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 723",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00011363"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from a law firm to a judge, discussing a court case involving Ghislaine Maxwell. The letter is typed and has a professional tone. There are no visible redactions or damage to the document."
}