mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003732.json

{
  "document_metadata": {
    "page_number": "8",
    "document_number": "208-1",
    "date": "04/16/2024",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 208-1 Filed 04/16/24 Page 8 of 10 issue, the Court finds that its action of striking the lurid details from Petitioners' submissions is sanction enough. However, the Court cautions that all counsel are subject to Rule 11's mandate that all submissions be presented for a proper purpose and factual contentions have evidentiary support, Fed. R. Civ. P. 11(b)(1) and (3), and that the Court may, on its own, strike from any pleading \"any redundant, immaterial, impertinent, or scandalous matter,\" Fed. R. Civ. P. 12(f). B. Rule 15 Motion Between their two motions (the Rule 21 Motion and Rule 15 Motion), Jane Doe 3 and Jane Doe 4 assert that \"they desire to join in this action to vindicate their rights [under the CVRA] as well.\" (DE 280 at 1). Although Petitioners already seek the invalidation of Mr. Epstein's non-prosecution agreement on behalf of all \"other similarly-situated victims\" (DE 189 at 1; DE 311 at 2, 12, 15, 18-19), Jane Doe 3 and Jane Doe 4 argue that they should be fellow travelers in this pursuit, lest they \"be forced to file a separate suit raising their claims\" resulting in \"duplicative litigation\" (DE 280 at 11). The Court finds that justice does not require adding new parties this late in the proceedings who will raise claims that are admittedly \"duplicative\" of the claims already presented by Petitioners. The Does' submissions demonstrate that it is entirely unnecessary for Jane Doe 3 and Jane Doe 4 to proceed as parties in this action, rather than as fact witnesses available to offer relevant, admissible, and non-cumulative testimony. (See, e.g., DE 280 at 2 (Jane Doe 3 and Jane Doe 4 \"are in many respects similarly situated to the current victims\"), 9 (\"The new victims will establish at trial that the Government violated their CVRA rights in the same way as it violated the rights of the other victims.\"), 10 (Jane Doe 3 and Jane Doe 4 \"will simply join in motions that the current victims were going to file in any event.\"), 11 (litigating Jane Doe 3 and 7 GIUFFRE002850 DOJ-OGR-00003732",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 208-1 Filed 04/16/24 Page 8 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "issue, the Court finds that its action of striking the lurid details from Petitioners' submissions is sanction enough. However, the Court cautions that all counsel are subject to Rule 11's mandate that all submissions be presented for a proper purpose and factual contentions have evidentiary support, Fed. R. Civ. P. 11(b)(1) and (3), and that the Court may, on its own, strike from any pleading \"any redundant, immaterial, impertinent, or scandalous matter,\" Fed. R. Civ. P. 12(f).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "B. Rule 15 Motion",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Between their two motions (the Rule 21 Motion and Rule 15 Motion), Jane Doe 3 and Jane Doe 4 assert that \"they desire to join in this action to vindicate their rights [under the CVRA] as well.\" (DE 280 at 1). Although Petitioners already seek the invalidation of Mr. Epstein's non-prosecution agreement on behalf of all \"other similarly-situated victims\" (DE 189 at 1; DE 311 at 2, 12, 15, 18-19), Jane Doe 3 and Jane Doe 4 argue that they should be fellow travelers in this pursuit, lest they \"be forced to file a separate suit raising their claims\" resulting in \"duplicative litigation\" (DE 280 at 11). The Court finds that justice does not require adding new parties this late in the proceedings who will raise claims that are admittedly \"duplicative\" of the claims already presented by Petitioners.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Does' submissions demonstrate that it is entirely unnecessary for Jane Doe 3 and Jane Doe 4 to proceed as parties in this action, rather than as fact witnesses available to offer relevant, admissible, and non-cumulative testimony. (See, e.g., DE 280 at 2 (Jane Doe 3 and Jane Doe 4 \"are in many respects similarly situated to the current victims\"), 9 (\"The new victims will establish at trial that the Government violated their CVRA rights in the same way as it violated the rights of the other victims.\"), 10 (Jane Doe 3 and Jane Doe 4 \"will simply join in motions that the current victims were going to file in any event.\"), 11 (litigating Jane Doe 3 and",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "7 GIUFFRE002850 DOJ-OGR-00003732",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jane Doe 3",
      "Jane Doe 4",
      "Epstein"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "04/16/2024"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "208-1",
      "DE 280",
      "DE 189",
      "DE 311"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Jeffrey Epstein. The text discusses the court's decision regarding the inclusion of additional parties in the case."
}