mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00019396.json

{
  "document_metadata": {
    "page_number": "3",
    "document_number": "54",
    "date": "09/23/2020",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 20-3061, Document 54, 09/23/2020, 2937091, Page3 of 6\n\ncase and to stay the unsealing process, just as it moved to intervene and to stay\ndiscovery in Doe v. Indyke, a civil case in which Jane Doe alleges that Epstein and\nMs. Maxwell abused and exploited her as a minor. According to the government, a\nstay of that case was necessary to “preserv[e] the integrity of the criminal\nprosecution against [Ms.] Maxwell.” Doe v. Indyke et al., No. 20-cv-00484, Doc.\n81, p 4, 9/14/2020 Order Granting Motion to Stay. The court there agreed, and it\ngranted Ms. Maxwell’s motion to stay. Id. at 12. This Court should not let the\ngovernment engage in such obvious gamesmanship.\n\nThe government insists that, in these two appeals, Ms. Maxwell is “ask[ing]\nthis Court to rule on . . . the lawfulness of the Government’s applications to modify\ncertain protective orders in other judicial proceedings.” Doc. 113, ¶ 27. That is not\nso. The government’s contention mischaracterizes Ms. Maxwell’s argument.\n\nAs Ms. Maxwell said in her opening brief:\n\nThe civil case is not the appropriate forum to litigate the\ngovernment’s apparent violation of Martindell. Ms. Maxwell intends\nto make that argument to Judge Nathan in the criminal case. But if\nJudge Preska’s unsealing order is affirmed and Ms. Maxwell’s\ndeposition is released, her ability to make that argument before Judge\nNathan will be prejudiced. Keeping the deposition material sealed will\npreserve the status quo and protect Ms. Maxwell’s right to litigate\nMartindell and the Fifth Amendment in the criminal proceeding.\nDoc. 69, p 33. Only by mischaracterizing Ms. Maxwell’s argument can the\ngovernment contend that she is “ask[ing] this Court to rule on . . . the lawfulness of\n\n3\nDOJ-OGR-00019396",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 20-3061, Document 54, 09/23/2020, 2937091, Page3 of 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "case and to stay the unsealing process, just as it moved to intervene and to stay\ndiscovery in Doe v. Indyke, a civil case in which Jane Doe alleges that Epstein and\nMs. Maxwell abused and exploited her as a minor. According to the government, a\nstay of that case was necessary to “preserv[e] the integrity of the criminal\nprosecution against [Ms.] Maxwell.” Doe v. Indyke et al., No. 20-cv-00484, Doc.\n81, p 4, 9/14/2020 Order Granting Motion to Stay. The court there agreed, and it\ngranted Ms. Maxwell’s motion to stay. Id. at 12. This Court should not let the\ngovernment engage in such obvious gamesmanship.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "The government insists that, in these two appeals, Ms. Maxwell is “ask[ing]\nthis Court to rule on . . . the lawfulness of the Government’s applications to modify\ncertain protective orders in other judicial proceedings.” Doc. 113, ¶ 27. That is not\nso. The government’s contention mischaracterizes Ms. Maxwell’s argument.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "As Ms. Maxwell said in her opening brief:",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "The civil case is not the appropriate forum to litigate the\ngovernment’s apparent violation of Martindell. Ms. Maxwell intends\nto make that argument to Judge Nathan in the criminal case. But if\nJudge Preska’s unsealing order is affirmed and Ms. Maxwell’s\ndeposition is released, her ability to make that argument before Judge\nNathan will be prejudiced. Keeping the deposition material sealed will\npreserve the status quo and protect Ms. Maxwell’s right to litigate\nMartindell and the Fifth Amendment in the criminal proceeding.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Doc. 69, p 33. Only by mischaracterizing Ms. Maxwell’s argument can the\ngovernment contend that she is “ask[ing] this Court to rule on . . . the lawfulness of",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "3",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00019396",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Ms. Maxwell",
      "Jane Doe",
      "Judge Preska",
      "Judge Nathan"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "09/23/2020",
      "9/14/2020"
    ],
    "reference_numbers": [
      "20-3061",
      "54",
      "20-cv-00484",
      "Doc. 81",
      "Doc. 113",
      "Doc. 69",
      "2937091",
      "DOJ-OGR-00019396"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, with references to other court documents and proceedings."
}