mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009600.json

{
  "document_metadata": {
    "page_number": "38",
    "document_number": "621",
    "date": "02/25/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 38 of 51\nPierre-Louis, 2018 WL 4043140, at *4-5 (death of a defense witness and defendant's own memory issues insufficient prejudice).\n\n2. Discussion\nThe defendant contends that she has suffered substantial prejudice due to the death of certain witnesses and the unavailability of certain documentary records. (Def. Mot. at 25-30). The defendant's speculative claims fail to establish substantial and actual prejudice caused by the allegedly excessive pre-indictment delay. See Birney, 686 F.2d at 105-06.\nThe defendant claims she has suffered substantial prejudice as a result of pre-indictment delay due to the unavailability of (1) Alberto Pinto and Roger Salhi, architects who worked for Epstein; (2) Sally Markham, “a property manager hired to help run Epstein's properties in the early 2000s”; and (3) Lynn Fontanilla, the live-in housekeeper in Epstein's New York townhouse. (Def. Mot. at 29-30).9 The defendant's speculative claims of prejudice do not withstand scrutiny. First, the fact that certain deceased witnesses cannot testify does not compel a finding of actual prejudice. “Unavailable witnesses are inherent in any delay, even if justifiable. To merit dismissal a defendant must demonstrate a substantial, actual prejudice to his ability to defend himself.” United\n9 The defendant also reasserts that the witnesses “already mentioned in [her] previous filings”— namely, Jeffrey Epstein, Epstein's mother, Michael Casey (the alleged agent of Minor Victim-1), and Palm Beach Police Department Detective Joseph Recarey—“could have provided evidence contradicting the government's proof.” (Def. Mot. at 29). The Court already rejected the defendant's claims of actual prejudice as to these witnesses, finding that the defendant “provide[d] no indication of what many of these potential witnesses might have testified to” and noting “serious doubts under all of the relevant circumstances that a jury would have found testimony from Epstein credible even if he had waived his right against self-incrimination and testified on her behalf.” (Dkt. No. 207 at 18). The defendant offers no new arguments as to these witnesses, and her claims certainly fare no better after the trial in this matter.\n37\nDOJ-OGR-00009600",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 38 of 51",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Pierre-Louis, 2018 WL 4043140, at *4-5 (death of a defense witness and defendant's own memory issues insufficient prejudice).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "2. Discussion",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The defendant contends that she has suffered substantial prejudice due to the death of certain witnesses and the unavailability of certain documentary records. (Def. Mot. at 25-30). The defendant's speculative claims fail to establish substantial and actual prejudice caused by the allegedly excessive pre-indictment delay. See Birney, 686 F.2d at 105-06.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant claims she has suffered substantial prejudice as a result of pre-indictment delay due to the unavailability of (1) Alberto Pinto and Roger Salhi, architects who worked for Epstein; (2) Sally Markham, “a property manager hired to help run Epstein's properties in the early 2000s”; and (3) Lynn Fontanilla, the live-in housekeeper in Epstein's New York townhouse. (Def. Mot. at 29-30).9 The defendant's speculative claims of prejudice do not withstand scrutiny. First, the fact that certain deceased witnesses cannot testify does not compel a finding of actual prejudice. “Unavailable witnesses are inherent in any delay, even if justifiable. To merit dismissal a defendant must demonstrate a substantial, actual prejudice to his ability to defend himself.” United",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "9 The defendant also reasserts that the witnesses “already mentioned in [her] previous filings”— namely, Jeffrey Epstein, Epstein's mother, Michael Casey (the alleged agent of Minor Victim-1), and Palm Beach Police Department Detective Joseph Recarey—“could have provided evidence contradicting the government's proof.” (Def. Mot. at 29). The Court already rejected the defendant's claims of actual prejudice as to these witnesses, finding that the defendant “provide[d] no indication of what many of these potential witnesses might have testified to” and noting “serious doubts under all of the relevant circumstances that a jury would have found testimony from Epstein credible even if he had waived his right against self-incrimination and testified on her behalf.” (Dkt. No. 207 at 18). The defendant offers no new arguments as to these witnesses, and her claims certainly fare no better after the trial in this matter.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "37",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009600",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Pierre-Louis",
      "Birney",
      "Alberto Pinto",
      "Roger Salhi",
      "Sally Markham",
      "Lynn Fontanilla",
      "Jeffrey Epstein",
      "Epstein's mother",
      "Michael Casey",
      "Joseph Recarey"
    ],
    "organizations": [
      "Palm Beach Police Department"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "02/25/22",
      "2018"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 621",
      "686 F.2d",
      "Dkt. No. 207"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and easy to read."
}