mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00019662.json

{
  "document_metadata": {
    "page_number": "16",
    "document_number": "94",
    "date": "10/08/2020",
    "document_type": "legal document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 20-3061, Document 94, 10/08/2020, 2948481, Page16 of 23\n\nArgument\n\nApart from obscuring the relief Ms. Maxwell actually seeks, the other major feature of the government's brief is its confusion of the arguments Ms. Maxwell actually makes on the merits. And nothing is more illustrative of the government's confusion than this fact: The answer brief doesn't even cite this Court's decision in Martindell.\n\nThe closest the government comes to acknowledging Ms. Maxwell's argument is to say this: \"To maintain the integrity of the grand jury investigation and in accordance with both Federal Rule of Criminal Procedure 6(e) and its standard practice, the Government did not notify Maxwell or her counsel of the Subpoenas.\" Ans.Br. 5. But standard practice doesn't justify circumventing a thirty-year-old decision of this Court, which required notice to Ms. Maxwell. Martindell, 594 F.2d at 294; App. 368-69\n\nMoreover, nothing in Rule 6(e) relieved the government of its burden to comply with Martindell by seeking to intervene in the civil case or by otherwise giving Ms. Maxwell notice of the subpoena and an opportunity to move to quash.\n\nRule 6(e)(2)(vi) says that \"an attorney for the government\" \"must not disclose a matter occurring before the grand jury.\" The was not a \"matter occurring before the grand jury.\" And\n\n13\n\nDOJ-OGR-00019662",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 20-3061, Document 94, 10/08/2020, 2948481, Page16 of 23",
      "position": "header"
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    {
      "type": "printed",
      "content": "Argument",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Apart from obscuring the relief Ms. Maxwell actually seeks, the other major feature of the government's brief is its confusion of the arguments Ms. Maxwell actually makes on the merits. And nothing is more illustrative of the government's confusion than this fact: The answer brief doesn't even cite this Court's decision in Martindell.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The closest the government comes to acknowledging Ms. Maxwell's argument is to say this: \"To maintain the integrity of the grand jury investigation and in accordance with both Federal Rule of Criminal Procedure 6(e) and its standard practice, the Government did not notify Maxwell or her counsel of the Subpoenas.\" Ans.Br. 5. But standard practice doesn't justify circumventing a thirty-year-old decision of this Court, which required notice to Ms. Maxwell. Martindell, 594 F.2d at 294; App. 368-69",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Moreover, nothing in Rule 6(e) relieved the government of its burden to comply with Martindell by seeking to intervene in the civil case or by otherwise giving Ms. Maxwell notice of the subpoena and an opportunity to move to quash.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Rule 6(e)(2)(vi) says that \"an attorney for the government\" \"must not disclose a matter occurring before the grand jury.\" The was not a \"matter occurring before the grand jury.\" And",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "13",
      "position": "footer"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00019662",
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  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "10/08/2020"
    ],
    "reference_numbers": [
      "20-3061",
      "94",
      "2948481",
      "DOJ-OGR-00019662"
    ]
  },
  "additional_notes": "The document appears to be a legal brief or court filing related to a case involving Ms. Maxwell. The text is mostly printed, with no handwritten content. There are no visible stamps or signatures. The document has a header with case information and a footer with a page number and a reference number."
}