mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003046.json

{
  "document_metadata": {
    "page_number": "112",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 112 of 239\n\nmarks omitted) (emphasis added)); In re “Agent Orange” Prod. Liab. Litig., 821 F.2d at 145 (“It is undisputed that a district court retains the power to modify or lift protective orders that it has entered.”). It also bears noting that Martindell and its progeny do not discuss law enforcement applications in Fourth Amendment terms.\n\nIn an effort to avoid the application of the third party doctrine, Maxwell contends that she did not in fact voluntarily share anything in the civil suit, and that “every other circumstance” supported her “expectation that her deposition transcripts would be private.” (Def. Mot. 11 at 9). Neither argument withstands scrutiny. As an initial matter, the facts of this case are far removed from the “narrow” circumstances in which the Supreme Court has found an exception to the third party doctrine. For example, the Carpenter Court, while stressing that its holding was a “narrow one,” 138 S. Ct. at 2220, held that “[g]iven the unique nature of cell phone location records,” which provide a “intimate window into a person’s life,” “the fact that the information is held by a third party does not by itself overcome the user’s claim to Fourth Amendment protection.” Id. at 2217; see also Zietzke v. United States, 426 F. Supp. 3d 758, 768 (W.D. Wash. 2019) (“The Court . . . will extend Carpenter to new circumstances only if they directly implicate the privacy concerns that animated the majority. [T]he majority was overwhelmingly concerned with ‘Carpenter’s anticipation of privacy in his physical location.’ In other words, Carpenter was about surveillance.” (internal citation omitted)).\n\nThere can be no serious argument that the facts of this case, or the materials obtained pursuant to the subpoena issued here, revealed Maxwell’s physical location over a period of time or are otherwise in any way analogous to the narrow category of information contemplated by the majority in Carpenter. To the extent the defendant argues that her deposition transcripts implicate such interests because she “did not ‘voluntarily convey’ her testimony to Giuffre,” (Def. Mot. 11\n\n85\n\nDOJ-OGR-00003046",
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      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 112 of 239",
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    {
      "type": "printed",
      "content": "marks omitted) (emphasis added)); In re “Agent Orange” Prod. Liab. Litig., 821 F.2d at 145 (“It is undisputed that a district court retains the power to modify or lift protective orders that it has entered.”). It also bears noting that Martindell and its progeny do not discuss law enforcement applications in Fourth Amendment terms.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In an effort to avoid the application of the third party doctrine, Maxwell contends that she did not in fact voluntarily share anything in the civil suit, and that “every other circumstance” supported her “expectation that her deposition transcripts would be private.” (Def. Mot. 11 at 9). Neither argument withstands scrutiny. As an initial matter, the facts of this case are far removed from the “narrow” circumstances in which the Supreme Court has found an exception to the third party doctrine. For example, the Carpenter Court, while stressing that its holding was a “narrow one,” 138 S. Ct. at 2220, held that “[g]iven the unique nature of cell phone location records,” which provide a “intimate window into a person’s life,” “the fact that the information is held by a third party does not by itself overcome the user’s claim to Fourth Amendment protection.” Id. at 2217; see also Zietzke v. United States, 426 F. Supp. 3d 758, 768 (W.D. Wash. 2019) (“The Court . . . will extend Carpenter to new circumstances only if they directly implicate the privacy concerns that animated the majority. [T]he majority was overwhelmingly concerned with ‘Carpenter’s anticipation of privacy in his physical location.’ In other words, Carpenter was about surveillance.” (internal citation omitted)).",
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    {
      "type": "printed",
      "content": "There can be no serious argument that the facts of this case, or the materials obtained pursuant to the subpoena issued here, revealed Maxwell’s physical location over a period of time or are otherwise in any way analogous to the narrow category of information contemplated by the majority in Carpenter. To the extent the defendant argues that her deposition transcripts implicate such interests because she “did not ‘voluntarily convey’ her testimony to Giuffre,” (Def. Mot. 11",
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    {
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      "content": "85",
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    {
      "type": "printed",
      "content": "DOJ-OGR-00003046",
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  ],
  "entities": {
    "people": [
      "Maxwell",
      "Giuffre",
      "Carpenter"
    ],
    "organizations": [
      "Supreme Court"
    ],
    "locations": [
      "W.D. Wash."
    ],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00003046"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, with a formal and technical tone. The text includes citations to legal precedents and references to specific court documents."
}