mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00015110.json

{
  "document_metadata": {
    "page_number": "15",
    "document_number": "804",
    "date": "08/06/25",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 804 Filed 08/06/25 Page 15 of 27\n\nHonorable Paul A. Engelmayer\nCase No.: 1:20-cr-00330 (PAE)\nPage 2\n\n- The right to be heard at any public proceeding involving release, parole, or sentencing (§ 3771(a)(3));\n- The right to confer with the attorney for the Government (§ 3771(a)(5)); and,\n- The right to be treated with fairness and respect for dignity and privacy (§ 3771(a)(8)).\n\nSee also Kenna v. U.S. Dist. Court, 435 F.3d 1011, 1016-17 (9th Cir. 2006) (fairness and dignity are substantive, enforceable rights); In re Dean, 527 F.3d 391, 394-95 (5th Cir. 2008) (government must confer with victims before making consequential case decisions); In re Wild, 994 F.3d 1244 (11th Cir. 2021) (en banc) (confirming that CVRA protections are fully attached post-conviction).\n\nCrucially, the victims' position regarding unsealing cannot be viewed in isolation as multiple developments are occurring simultaneously:\n\n- Maxwell's New Platform and Public Legitimization: Despite being convicted on federal sex trafficking charges, Maxwell has been given a public platform to speak with highly influential individuals such as Deputy Attorney General Todd Blanche, as though she were a credible authority. That is particularly jarring given that she was charged with multiple sex-trafficking offenses and two counts of perjury arising from civil depositions on these very subjects. To be clear, we do not take issue with Mr. Blanche meeting with Ms. Maxwell, seemingly at Maxwell's request, to obtain gratuitous information she wants to provide. However, for survivors who bravely testified, the perception that Ms. Maxwell is being legitimized in public discourse has already resulted in re-traumatization.\n\n- Transfer to a Lower-Security Facility: Maxwell's recent move to a lower-security prison has further eroded the victims' confidence that their safety and dignity are priorities. The transfer was made without prior notice to the victims, without opportunity to object, and without explanation—actions they see as extraordinarily insensitive and suggestive of ulterior purposes.\n\n- Lack of Consultation on Unsealing: The government sought the unsealing of grand jury materials before this Court without first conferring with the victims or their counsel, a step required by the CVRA and reinforced by Doe v. United States, 08-80736 (S.D. Fla.). That case, litigated pro bono by undersigned counsel for more than a decade, arose precisely because the government previously violated the rights of many of these very same victims. It is especially troubling that, despite the outcome of that litigation, the government has once again proceeded in a manner that disregards the victims' rights—suggesting that the hard-learned lessons of the past have not taken hold. This omission reinforces the perception that the victims are, at best, an afterthought to the current administration.\n\n- Concrete Fear of Clemency: Survivors are acutely concerned that unsealing, coupled with the transfer and Ms. Maxwell's public platform, may be a prelude to clemency. The risk of a pardon or commutation exacerbates safety concerns in derogation of § 3771(a)(1), and threatens severe psychological harm, including triggering trauma responses. For\n\nDOJ-OGR-00015110",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 804 Filed 08/06/25 Page 15 of 27",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Honorable Paul A. Engelmayer\nCase No.: 1:20-cr-00330 (PAE)\nPage 2",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "- The right to be heard at any public proceeding involving release, parole, or sentencing (§ 3771(a)(3));\n- The right to confer with the attorney for the Government (§ 3771(a)(5)); and,\n- The right to be treated with fairness and respect for dignity and privacy (§ 3771(a)(8)).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "See also Kenna v. U.S. Dist. Court, 435 F.3d 1011, 1016-17 (9th Cir. 2006) (fairness and dignity are substantive, enforceable rights); In re Dean, 527 F.3d 391, 394-95 (5th Cir. 2008) (government must confer with victims before making consequential case decisions); In re Wild, 994 F.3d 1244 (11th Cir. 2021) (en banc) (confirming that CVRA protections are fully attached post-conviction).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Crucially, the victims' position regarding unsealing cannot be viewed in isolation as multiple developments are occurring simultaneously:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- Maxwell's New Platform and Public Legitimization: Despite being convicted on federal sex trafficking charges, Maxwell has been given a public platform to speak with highly influential individuals such as Deputy Attorney General Todd Blanche, as though she were a credible authority. That is particularly jarring given that she was charged with multiple sex-trafficking offenses and two counts of perjury arising from civil depositions on these very subjects. To be clear, we do not take issue with Mr. Blanche meeting with Ms. Maxwell, seemingly at Maxwell's request, to obtain gratuitous information she wants to provide. However, for survivors who bravely testified, the perception that Ms. Maxwell is being legitimized in public discourse has already resulted in re-traumatization.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- Transfer to a Lower-Security Facility: Maxwell's recent move to a lower-security prison has further eroded the victims' confidence that their safety and dignity are priorities. The transfer was made without prior notice to the victims, without opportunity to object, and without explanation—actions they see as extraordinarily insensitive and suggestive of ulterior purposes.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- Lack of Consultation on Unsealing: The government sought the unsealing of grand jury materials before this Court without first conferring with the victims or their counsel, a step required by the CVRA and reinforced by Doe v. United States, 08-80736 (S.D. Fla.). That case, litigated pro bono by undersigned counsel for more than a decade, arose precisely because the government previously violated the rights of many of these very same victims. It is especially troubling that, despite the outcome of that litigation, the government has once again proceeded in a manner that disregards the victims' rights—suggesting that the hard-learned lessons of the past have not taken hold. This omission reinforces the perception that the victims are, at best, an afterthought to the current administration.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- Concrete Fear of Clemency: Survivors are acutely concerned that unsealing, coupled with the transfer and Ms. Maxwell's public platform, may be a prelude to clemency. The risk of a pardon or commutation exacerbates safety concerns in derogation of § 3771(a)(1), and threatens severe psychological harm, including triggering trauma responses. For",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00015110",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Paul A. Engelmayer",
      "Todd Blanche",
      "Maxwell",
      "Mr. Blanche",
      "Ms. Maxwell"
    ],
    "organizations": [
      "U.S. Dist. Court",
      "Government"
    ],
    "locations": [
      "Florida"
    ],
    "dates": [
      "08/06/25",
      "2006",
      "2008",
      "2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 804",
      "08-80736",
      "DOJ-OGR-00015110"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell, discussing the rights of victims and concerns regarding her treatment and potential clemency."
}