mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00010428.json

{
  "document_metadata": {
    "page_number": "11",
    "document_number": "662",
    "date": "06/15/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page 11 of 29\nevidence indicates that Carolyn stopped performing sexualized massages for Epstein at the latest in the summer of 2004, not in 2005.5\nThe two message pad slips cited by the government (GX 4-B, GX 4-F) do not support a finding that the offense conduct lasted beyond November 1, 2004. Although these two messages were labeled as government exhibits along with the rest of the message slips in the same book (GX 4-A-K), these messages were never admitted in evidence. The Court admitted the message slips from three other message books (GX 1-3) because Juan Alessi and Nicole Hesse recognized their signatures and/or handwriting in those books and could establish a business records foundation for their admission. (Tr. 877-889, 1772-1790). The government presumably did not have anyone who could do the same for GX 4 or it would certainly have admitted the message slips from that book as well. The Court should not rely on two isolated, unauthenticated documents in determining when the offense conduct ended, especially when they would almost single-handedly increase the recommended sentencing range by over 10 years. Cf. United States v. Cordoba-Murgas, 233 F.3d 704, 708 (2d Cir. 2000) (acknowledging that enhancements based on relevant conduct may result in sentences that are \"excessive, inappropriate, and unintended under Sentencing Guidelines\" when imposed \"without regard to the weight of the evidence proving the relevant conduct\"); United States v. Gigante, 94 F.3d 53, 56 (2d Cir. 1996) (holding that, for sentencing purposes, \"the preponderance standard is no more than a threshold basis for adjustments and departures, and the weight of the evidence, at some point along a continuum of sentence severity, should be considered\") (emphasis in original).\n5 In her 2007 interview with the FBI, which the government cites in its own objections to the PSR, Carolyn stated that she went to Epstein's residence \"over 100 times for approximately three years beginning when she was 14 years old.\" See PSR at 54. According to that timeline, Carolyn last visited Epstein when she was 17.\n7\nDOJ-OGR-00010428",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page 11 of 29",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "evidence indicates that Carolyn stopped performing sexualized massages for Epstein at the latest in the summer of 2004, not in 2005.5\nThe two message pad slips cited by the government (GX 4-B, GX 4-F) do not support a finding that the offense conduct lasted beyond November 1, 2004. Although these two messages were labeled as government exhibits along with the rest of the message slips in the same book (GX 4-A-K), these messages were never admitted in evidence. The Court admitted the message slips from three other message books (GX 1-3) because Juan Alessi and Nicole Hesse recognized their signatures and/or handwriting in those books and could establish a business records foundation for their admission. (Tr. 877-889, 1772-1790). The government presumably did not have anyone who could do the same for GX 4 or it would certainly have admitted the message slips from that book as well. The Court should not rely on two isolated, unauthenticated documents in determining when the offense conduct ended, especially when they would almost single-handedly increase the recommended sentencing range by over 10 years. Cf. United States v. Cordoba-Murgas, 233 F.3d 704, 708 (2d Cir. 2000) (acknowledging that enhancements based on relevant conduct may result in sentences that are \"excessive, inappropriate, and unintended under Sentencing Guidelines\" when imposed \"without regard to the weight of the evidence proving the relevant conduct\"); United States v. Gigante, 94 F.3d 53, 56 (2d Cir. 1996) (holding that, for sentencing purposes, \"the preponderance standard is no more than a threshold basis for adjustments and departures, and the weight of the evidence, at some point along a continuum of sentence severity, should be considered\") (emphasis in original).",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "5 In her 2007 interview with the FBI, which the government cites in its own objections to the PSR, Carolyn stated that she went to Epstein's residence \"over 100 times for approximately three years beginning when she was 14 years old.\" See PSR at 54. According to that timeline, Carolyn last visited Epstein when she was 17.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "7",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010428",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Carolyn",
      "Epstein",
      "Juan Alessi",
      "Nicole Hesse"
    ],
    "organizations": [
      "FBI"
    ],
    "locations": [],
    "dates": [
      "2004",
      "2005",
      "2007",
      "November 1, 2004",
      "06/15/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "662",
      "GX 4-B",
      "GX 4-F",
      "GX 4-A-K",
      "GX 1-3",
      "Tr. 877-889",
      "1772-1790",
      "PSR at 54",
      "DOJ-OGR-00010428"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case United States v. Epstein. The text discusses the evidence presented in the case and the sentencing guidelines. There are no visible redactions or damage to the document."
}