mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011374.json

{
  "document_metadata": {
    "page_number": "12",
    "document_number": "723",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 723 Filed 07/12/22 Page 12 of 13\nThe Honorable Alison J. Nathan December 16, 2021 Page 12\nevidence. Gov. Letter, pp 3, 8. Even if that is what those cases hold (which Ms. Maxwell disputes), the cases have no applicability here, because the details of the sexualized massages are not collateral issues. They are the central issues in this case.\nAt best, the government's arguments go to weight, not admissibility. If the government wants to argue that Eva Dubin, Michelle Healy, and Kelly Bovino are not the Eva, Michelle, and Kelly who Jane was referring to, the government is free to make that argument. In fact, the government has already made precisely that argument as to , responding to the flight logs' use of the name . But that argument is no basis for denying Ms. Maxwell her constitutional right to present a defense. U.S. Const. amends. V, VI.\nCONCLUSION\nThis Court should deny the government's motion.\nDOJ-OGR-00011374",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 723 Filed 07/12/22 Page 12 of 13",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan December 16, 2021 Page 12",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "evidence. Gov. Letter, pp 3, 8. Even if that is what those cases hold (which Ms. Maxwell disputes), the cases have no applicability here, because the details of the sexualized massages are not collateral issues. They are the central issues in this case.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "At best, the government's arguments go to weight, not admissibility. If the government wants to argue that Eva Dubin, Michelle Healy, and Kelly Bovino are not the Eva, Michelle, and Kelly who Jane was referring to, the government is free to make that argument. In fact, the government has already made precisely that argument as to , responding to the flight logs' use of the name . But that argument is no basis for denying Ms. Maxwell her constitutional right to present a defense. U.S. Const. amends. V, VI.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "CONCLUSION",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "This Court should deny the government's motion.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011374",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell",
      "Eva Dubin",
      "Michelle Healy",
      "Kelly Bovino",
      "Jane"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "December 16, 2021",
      "07/12/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 723"
    ]
  },
  "additional_notes": "The document appears to be a court filing with some redacted text. The redactions are represented by blacked-out boxes."
}