mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003115.json

{
  "document_metadata": {
    "page_number": "181",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "is particularly instructive here. See 386 F. Supp.3d at 366. In denying the motion to dismiss, Judge Marrero found Stringer's holding \"that the identity of a victim was not required to be contained in an indictment, despite the centrality of the victim's identity to the charge\" to be equally applicable in a case involving sex trafficking charges. Id. at 369. The same logic follows here. The use of pseudonyms to refer to the minor victims of sexual abuse in Counts One through Four is no more prejudicial to the defendant here than the absence of victim identities was to the defendants in Kidd or Stringer. This is especially so when the Government has already provided the defendant with the birth month and year of each victim, provided discovery regarding each victim, and has repeatedly indicated that it will provide the defendant with the names of its witnesses, including the minor victims referenced in the Indictment, four weeks in advance of trial. Such disclosure will ensure that the defendant is readily able to bar future prosecutions for the same offense, and together with the elements of each crime and additional details contained in in the Indictment, is more than sufficient to survive a motion to dismiss.\n\nSecond, the Indictment \"state[s] the time and place (in approximate terms)\" of the conduct alleged in Counts One through Four. Stavroulakis, 952 F.2d at 693 (quoting Tramunti, 513 F.2d at 1113). In particular, Counts One through Four each allege that the defendant engaged in a continuing course of conduct involving the enticement and transportation of minors with intent to commit illegal sex acts, as well as conspiracies to do so, between in or about 1994 and in or about 1997. See Indictment ¶¶ 1, 6, 7, 9-11, 13, 15-17, 19. Courts in the Second Circuit have consistently upheld indictments containing a range of time rather than a specific date. See, e.g., Kidd, 386 F. Supp. 3d at 369 (\"[Th]e Second Circuit routinely upholds the 'on or about' language used to describe the window of when a violation occurred.\" (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987))); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL",
  "text_blocks": [
    {
      "type": "printed",
      "content": "is particularly instructive here. See 386 F. Supp.3d at 366. In denying the motion to dismiss, Judge Marrero found Stringer's holding \"that the identity of a victim was not required to be contained in an indictment, despite the centrality of the victim's identity to the charge\" to be equally applicable in a case involving sex trafficking charges. Id. at 369. The same logic follows here. The use of pseudonyms to refer to the minor victims of sexual abuse in Counts One through Four is no more prejudicial to the defendant here than the absence of victim identities was to the defendants in Kidd or Stringer. This is especially so when the Government has already provided the defendant with the birth month and year of each victim, provided discovery regarding each victim, and has repeatedly indicated that it will provide the defendant with the names of its witnesses, including the minor victims referenced in the Indictment, four weeks in advance of trial. Such disclosure will ensure that the defendant is readily able to bar future prosecutions for the same offense, and together with the elements of each crime and additional details contained in in the Indictment, is more than sufficient to survive a motion to dismiss.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Second, the Indictment \"state[s] the time and place (in approximate terms)\" of the conduct alleged in Counts One through Four. Stavroulakis, 952 F.2d at 693 (quoting Tramunti, 513 F.2d at 1113). In particular, Counts One through Four each allege that the defendant engaged in a continuing course of conduct involving the enticement and transportation of minors with intent to commit illegal sex acts, as well as conspiracies to do so, between in or about 1994 and in or about 1997. See Indictment ¶¶ 1, 6, 7, 9-11, 13, 15-17, 19. Courts in the Second Circuit have consistently upheld indictments containing a range of time rather than a specific date. See, e.g., Kidd, 386 F. Supp. 3d at 369 (\"[Th]e Second Circuit routinely upholds the 'on or about' language used to describe the window of when a violation occurred.\" (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987))); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL",
      "position": "main body"
    }
  ],
  "entities": {
    "people": [
      "Marrero",
      "Stringer",
      "Kidd",
      "Stavroulakis",
      "Tramunti",
      "Nersesian",
      "Vickers"
    ],
    "organizations": [
      "Government",
      "Second Circuit"
    ],
    "locations": [],
    "dates": [
      "04/16/21",
      "1994",
      "1997"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 204",
      "386 F. Supp.3d",
      "952 F.2d",
      "513 F.2d",
      "824 F.2d",
      "No. 13 Cr. 128 (RJA) (HKS)"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, specifically discussing the sufficiency of an indictment. The text is printed and there are no visible stamps or handwritten notes. The document is likely a page from a larger filing, as indicated by the page number and document number at the top."
}