mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011204.json

{
  "document_metadata": {
    "page_number": "2 of 2",
    "document_number": "702-3",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 702-3 Filed 07/12/22 Page 2 of 2\n\n5. We made diligent efforts to contact Ms. Bovino and even to put her on call for the testimony.\n6. Ms. Bovino has not responded to our attempts to contact her.\n7. She has not appeared as commanded by the subpoena.\n8. Because Ms. Bovino has refused to comply with the subpoena, it is \"impracticable to secure the presence of the person by subpoena\" under the statute. § 3144.\n9. And because the trial is ongoing, and because Ms. Bovino is not responding to our attempts to contact her, her testimony \"can[not] adequately be secured by deposition.\" § 3144.\n10. Accordingly, under 28 U.S.C. § 3144, this Court can order Ms. Bovino's arrest.\n\nI hereby certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements are willfully false, I am subject to punishment.\n\nDated: December 17, 2021.\nNew York, New York\n\ns/ Laura A. Menninger\nLaura A. Menninger\nHADDON, MORGAN AND FOREMAN, P.C.\n150 East 10th Avenue\nDenver, CO 80203\n303.831.7364\n\nDOJ-OGR-00011204",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 702-3 Filed 07/12/22 Page 2 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "5. We made diligent efforts to contact Ms. Bovino and even to put her on call for the testimony.\n6. Ms. Bovino has not responded to our attempts to contact her.\n7. She has not appeared as commanded by the subpoena.\n8. Because Ms. Bovino has refused to comply with the subpoena, it is \"impracticable to secure the presence of the person by subpoena\" under the statute. § 3144.\n9. And because the trial is ongoing, and because Ms. Bovino is not responding to our attempts to contact her, her testimony \"can[not] adequately be secured by deposition.\" § 3144.\n10. Accordingly, under 28 U.S.C. § 3144, this Court can order Ms. Bovino's arrest.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "I hereby certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements are willfully false, I am subject to punishment.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dated: December 17, 2021.\nNew York, New York",
      "position": "middle"
    },
    {
      "type": "signature",
      "content": "s/ Laura A. Menninger",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "Laura A. Menninger\nHADDON, MORGAN AND FOREMAN, P.C.\n150 East 10th Avenue\nDenver, CO 80203\n303.831.7364",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011204",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Bovino",
      "Laura A. Menninger"
    ],
    "organizations": [
      "HADDON, MORGAN AND FOREMAN, P.C."
    ],
    "locations": [
      "New York",
      "Denver, CO"
    ],
    "dates": [
      "December 17, 2021",
      "07/12/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "702-3",
      "28 U.S.C. § 3144",
      "DOJ-OGR-00011204"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. It is a typed document with a signature block at the end. There are no visible redactions or damage."
}