DOJ-OGR-00003737.json 5.2 KB

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  1. {
  2. "document_metadata": {
  3. "page_number": "2 of 15",
  4. "document_number": "208-2",
  5. "date": "04/16/21",
  6. "document_type": "Court Document",
  7. "has_handwriting": false,
  8. "has_stamps": false
  9. },
  10. "full_text": "Case 1:20-cr-00330-PAE Document 208-2 Filed 04/16/21 Page 2 of 15\nCase 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 1 of 14\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF FLORIDA\n\nCase No. 08-80736-Civ-Marra/Johnson\n\nJANE DOE #1 and JANE DOE #2\n\nv.\n\nUNITED STATES\n\nJANE DOE #3 AND JANE DOE #4's CORRECTED MOTION PURSUANT TO RULE 21 FOR JOINDER IN ACTION\n\nCOME NOW Jane Doe #3 and Jane Doe #4 (also referred to as \"the new victims\"), by and through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21 to join this action, on the condition that they not re-litigate any issues already litigated by Jane Doe #1 and Jane Doe #2 (also referred to as \"the current victims\"). The new victims have suffered the same violations of their rights under the Crime Victims' Rights Act (CVRA) as the current victims. Accordingly, they desire to join in this action to vindicate their rights as well.\n\nBecause the new victims will not re-litigate any issues previously litigated by the current victims (and because they are represented by the same legal counsel as the current victims), the Government will not be prejudiced if the Court grants the motion. The Court may \"at any time\" add new parties to the action, Fed. R. Civ. P. 21. Accordingly, the Court should grant the motion.1\n\nFACTUAL BACKGROUND\n\n1 As minor victims of sexual offenses, Jane Doe #3 and Jane Doe #4 desire to proceed by way of pseudonym for the same reasons that Jane Doe #1 and Jane Doe #2 proceeded in this fashion. Counsel for the new victims have made their true identities known to the Government.\n\nGIUFFRE 004288\nCONFIDENTIAL\nDOJ-OGR-00003737",
  11. "text_blocks": [
  12. {
  13. "type": "printed",
  14. "content": "Case 1:20-cr-00330-PAE Document 208-2 Filed 04/16/21 Page 2 of 15",
  15. "position": "header"
  16. },
  17. {
  18. "type": "printed",
  19. "content": "Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 1 of 14",
  20. "position": "header"
  21. },
  22. {
  23. "type": "printed",
  24. "content": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA",
  25. "position": "header"
  26. },
  27. {
  28. "type": "printed",
  29. "content": "Case No. 08-80736-Civ-Marra/Johnson",
  30. "position": "header"
  31. },
  32. {
  33. "type": "printed",
  34. "content": "JANE DOE #1 and JANE DOE #2 v. UNITED STATES",
  35. "position": "header"
  36. },
  37. {
  38. "type": "printed",
  39. "content": "JANE DOE #3 AND JANE DOE #4's CORRECTED MOTION PURSUANT TO RULE 21 FOR JOINDER IN ACTION",
  40. "position": "header"
  41. },
  42. {
  43. "type": "printed",
  44. "content": "COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as \"the new victims\"), by and through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21 to join this action, on the condition that they not re-litigate any issues already litigated by Jane Doe #1 and Jane Doe #2 (also referred to as \"the current victims\"). The new victims have suffered the same violations of their rights under the Crime Victims' Rights Act (CVRA) as the current victims. Accordingly, they desire to join in this action to vindicate their rights as well.",
  45. "position": "body"
  46. },
  47. {
  48. "type": "printed",
  49. "content": "Because the new victims will not re-litigate any issues previously litigated by the current victims (and because they are represented by the same legal counsel as the current victims), the Government will not be prejudiced if the Court grants the motion. The Court may \"at any time\" add new parties to the action, Fed. R. Civ. P. 21. Accordingly, the Court should grant the motion.",
  50. "position": "body"
  51. },
  52. {
  53. "type": "printed",
  54. "content": "FACTUAL BACKGROUND",
  55. "position": "header"
  56. },
  57. {
  58. "type": "printed",
  59. "content": "1 As minor victims of sexual offenses, Jane Doe #3 and Jane Doe #4 desire to proceed by way of pseudonym for the same reasons that Jane Doe #1 and Jane Doe #2 proceeded in this fashion. Counsel for the new victims have made their true identities known to the Government.",
  60. "position": "body"
  61. },
  62. {
  63. "type": "printed",
  64. "content": "GIUFFRE 004288 CONFIDENTIAL DOJ-OGR-00003737",
  65. "position": "footer"
  66. }
  67. ],
  68. "entities": {
  69. "people": [
  70. "Jane Doe #1",
  71. "Jane Doe #2",
  72. "Jane Doe #3",
  73. "Jane Doe #4"
  74. ],
  75. "organizations": [
  76. "UNITED STATES DISTRICT COURT",
  77. "SOUTHERN DISTRICT OF FLORIDA"
  78. ],
  79. "locations": [
  80. "Florida"
  81. ],
  82. "dates": [
  83. "04/16/21",
  84. "01/02/2015"
  85. ],
  86. "reference_numbers": [
  87. "Case 1:20-cr-00330-PAE",
  88. "Case 9:08-cv-80736-KAM",
  89. "Case No. 08-80736-Civ-Marra/Johnson",
  90. "GIUFFRE 004288",
  91. "DOJ-OGR-00003737"
  92. ]
  93. },
  94. "additional_notes": "The document appears to be a court filing related to a case involving Jane Doe #1, Jane Doe #2, Jane Doe #3, and Jane Doe #4. The document is marked as 'CONFIDENTIAL' and contains a reference number 'GIUFFRE 004288' and 'DOJ-OGR-00003737'."
  95. }