DOJ-OGR-00021726.json 4.4 KB

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  1. {
  2. "document_metadata": {
  3. "page_number": "79",
  4. "document_number": "22-1426, Document 79",
  5. "date": "06/29/2023",
  6. "document_type": "court document",
  7. "has_handwriting": false,
  8. "has_stamps": false
  9. },
  10. "full_text": "Case 22-1426, Document 79, 06/29/2023, 3536060, Page79 of 93\n\n66\nnot constitute \"extraneous\" information. Warger v. Shauers, 574 U.S. 40, 51-52 (2014) (rejecting party's attempt to use the \"extraneous\" information exception to establish that a juror should have been excluded under McDonough based on his personal experiences).\n\nPOINT IV\n\nThe District Court's Response to a Jury Note Did Not Constructively Amend the Indictment\n\nAt all times the Government consistently argued that Maxwell enticed and transported Jane to New York with the intent that Jane engage in illegal sexual activity, and that Maxwell conspired to do so regarding Jane and the other victims. That is the issue Judge Nathan instructed the jury to resolve, and that is the criminal conduct charged in Counts Three and Four of the Indictment. Accordingly, no constructive amendment or variance occurred.\n\nA. Relevant Facts\n\nCounts Three and Four charged Maxwell with arranging for Jane's transportation to New York with the intent that Jane would engage in sex acts with Epstein, in violation of New York state law, and with a conspiracy to transport minors to New York for the same purpose. (A.127-30). At trial, the Government marshalled evidence that Maxwell transported Jane to New York, and aided and abetted Epstein in doing so, with the intent that Jane engage in sexual activity there. That evidence included detailed testimony from Jane about Epstein's New York residence (Tr.316-19)\n\nDOJ-OGR-00021726",
  11. "text_blocks": [
  12. {
  13. "type": "printed",
  14. "content": "Case 22-1426, Document 79, 06/29/2023, 3536060, Page79 of 93",
  15. "position": "header"
  16. },
  17. {
  18. "type": "printed",
  19. "content": "66\nnot constitute \"extraneous\" information. Warger v. Shauers, 574 U.S. 40, 51-52 (2014) (rejecting party's attempt to use the \"extraneous\" information exception to establish that a juror should have been excluded under McDonough based on his personal experiences).",
  20. "position": "top"
  21. },
  22. {
  23. "type": "printed",
  24. "content": "POINT IV\n\nThe District Court's Response to a Jury Note Did Not Constructively Amend the Indictment",
  25. "position": "middle"
  26. },
  27. {
  28. "type": "printed",
  29. "content": "At all times the Government consistently argued that Maxwell enticed and transported Jane to New York with the intent that Jane engage in illegal sexual activity, and that Maxwell conspired to do so regarding Jane and the other victims. That is the issue Judge Nathan instructed the jury to resolve, and that is the criminal conduct charged in Counts Three and Four of the Indictment. Accordingly, no constructive amendment or variance occurred.",
  30. "position": "middle"
  31. },
  32. {
  33. "type": "printed",
  34. "content": "A. Relevant Facts\n\nCounts Three and Four charged Maxwell with arranging for Jane's transportation to New York with the intent that Jane would engage in sex acts with Epstein, in violation of New York state law, and with a conspiracy to transport minors to New York for the same purpose. (A.127-30). At trial, the Government marshalled evidence that Maxwell transported Jane to New York, and aided and abetted Epstein in doing so, with the intent that Jane engage in sexual activity there. That evidence included detailed testimony from Jane about Epstein's New York residence (Tr.316-19)",
  35. "position": "middle"
  36. },
  37. {
  38. "type": "printed",
  39. "content": "DOJ-OGR-00021726",
  40. "position": "footer"
  41. }
  42. ],
  43. "entities": {
  44. "people": [
  45. "Maxwell",
  46. "Jane",
  47. "Epstein",
  48. "Judge Nathan",
  49. "McDonough"
  50. ],
  51. "organizations": [
  52. "Government"
  53. ],
  54. "locations": [
  55. "New York"
  56. ],
  57. "dates": [
  58. "06/29/2023",
  59. "2014"
  60. ],
  61. "reference_numbers": [
  62. "22-1426",
  63. "Document 79",
  64. "3536060",
  65. "Page79 of 93",
  66. "574 U.S. 40",
  67. "A.127-30",
  68. "Tr.316-19",
  69. "DOJ-OGR-00021726"
  70. ]
  71. },
  72. "additional_notes": "The document appears to be a court filing related to the case of Maxwell, with references to specific counts and legal precedents. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
  73. }