mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011461.json

{
  "document_metadata": {
    "page_number": "11",
    "document_number": "734",
    "date": "07/15/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page 11 of 16\n\nNovember 19, 2021\nPage Eleven\n\nIslands' probate court order approving the program—and the associated, mandatory confidentiality protections of the Protocol—provides yet another reason to quash the subpoena.47 See THCF Med. Clinic Recs., 504 F. Supp. 2d at 1090 (quashing subpoena in part where, by complying, state “would be violating its own laws”). Because compliance would be unreasonable or oppressive, this Court should quash the subpoena.\n\nCompliance would also be unreasonable or oppressive because all the information Maxwell seeks is “otherwise procurable” or, indeed, already in Ms. Maxwell's possession. See United States v. Pena, No. 15 Cr. 551 (AJN), 2016 WL 8735699, at *2 (S.D.N.Y. Feb. 12, 2016) (subpoena proponent must show materials are “not otherwise procurable” (citation omitted)). As noted, Maxwell previously sought to subpoena Boies Schiller and four individuals for EVCP material and was denied without prejudice,48 but she apparently has not sought to renew those requests. Instead, she decided to direct her subpoena at a different source: the EVCP's administrator. While the EVCP cannot divine the reason behind that shift in legal strategy, it appears as if she is attempting to do an end run around the Court's prior rulings or believes that renewing those requests will be unfruitful. The EVCP is not suggesting that Ms. Maxwell renew her earlier requests directed at EVCP claimants. The EVCP believes that no participant should be required to turn over their confidential submissions against their wishes. But there are alternative ways to obtain the information she seeks, such as on cross-examination at trial, to the extent permissible. And—in the case of releases Maxwell seeks—at least two courts in this\n\n47 See Ex. A ¶ 13 (Feldman Decl.).\n48 ECF Nos. 252, 334.\n\nDOJ-OGR-00011461",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 734 Filed 07/15/22 Page 11 of 16",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "November 19, 2021\nPage Eleven",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Islands' probate court order approving the program—and the associated, mandatory confidentiality protections of the Protocol—provides yet another reason to quash the subpoena.47 See THCF Med. Clinic Recs., 504 F. Supp. 2d at 1090 (quashing subpoena in part where, by complying, state “would be violating its own laws”). Because compliance would be unreasonable or oppressive, this Court should quash the subpoena.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Compliance would also be unreasonable or oppressive because all the information Maxwell seeks is “otherwise procurable” or, indeed, already in Ms. Maxwell's possession. See United States v. Pena, No. 15 Cr. 551 (AJN), 2016 WL 8735699, at *2 (S.D.N.Y. Feb. 12, 2016) (subpoena proponent must show materials are “not otherwise procurable” (citation omitted)). As noted, Maxwell previously sought to subpoena Boies Schiller and four individuals for EVCP material and was denied without prejudice,48 but she apparently has not sought to renew those requests. Instead, she decided to direct her subpoena at a different source: the EVCP's administrator. While the EVCP cannot divine the reason behind that shift in legal strategy, it appears as if she is attempting to do an end run around the Court's prior rulings or believes that renewing those requests will be unfruitful. The EVCP is not suggesting that Ms. Maxwell renew her earlier requests directed at EVCP claimants. The EVCP believes that no participant should be required to turn over their confidential submissions against their wishes. But there are alternative ways to obtain the information she seeks, such as on cross-examination at trial, to the extent permissible. And—in the case of releases Maxwell seeks—at least two courts in this",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "47 See Ex. A ¶ 13 (Feldman Decl.).\n48 ECF Nos. 252, 334.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011461",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Pena",
      "Feldman"
    ],
    "organizations": [
      "Boies Schiller",
      "EVCP"
    ],
    "locations": [
      "United States",
      "S.D.N.Y."
    ],
    "dates": [
      "November 19, 2021",
      "07/15/22",
      "Feb. 12, 2016"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 734",
      "15 Cr. 551 (AJN)",
      "2016 WL 8735699",
      "ECF Nos. 252, 334",
      "DOJ-OGR-00011461"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case United States v. Maxwell. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
}