mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011246.json

{
  "document_metadata": {
    "page_number": "6",
    "document_number": "705",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 705 Filed 07/12/22 Page 6 of 12\nThe Honorable Alison J. Nathan\nMay 12, 2021\nPage 6\nof 3500 Material: (1) a statement by the witness, (2) in the possession of the United States, (3)\nthat relates to the subject matter of the witness's testimony.\")\nThis case now involves a ten-year time period beginning 27 years ago. The indictment\nand the accusers are vague regarding when things happened, what things happened and who may\nhave been present when anything is alleged to have happened. Accuser-2's journal contains\ndated entries that place events in context with other alleged events. Accuser-2's journal from\n1996 purports to document encounters with Epstein in New York. The S2 indictment, paragraph\n9(b), claims that “Maxwell interacted with [Accuser-2] on at least one occasion in or about 1996\nat Epstein's residence in New Mexico….” The journal references other dates, places, and events\nin 1996. The absence of any mention of Ms. Maxwell in context with other recorded events is\nboth relevant and exculpatory.\nAs a piece of physical evidence, the journal is subject to inspection and testing. See F. R.\nCrim. P. 17(c)(1). Moreover, were the journal in the possession of the government it would be\nsubject to inspection under F. R. Crim. P. 16 (a) (1) (E) which provides, in relevant part:\nUpon a defendant's request, the government must permit the defendant to\ninspect and to copy or photograph books, papers, documents, data,\nphotographs, tangible objects, buildings or places, or copies or portions of\nany of these items, if the item is within the government's possession,\ncustody, or control and:\n(i) the item is material to preparing the defense;\n(ii) the government intends to use the item in its case-in-chief at trial[.]\nTo avoid any disclosure obligations, the government has simply accepted partisan\nphotocopies of five substantive pages without questioning the provenance of an exhibit it intends\nto introduce at trial. Comparison of one of the five pages demonstrates the problem. Attached as\nexhibit A is a photocopy of a journal entry first produced during the civil litigation. A photocopy\nDOJ-OGR-00011246",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 705 Filed 07/12/22 Page 6 of 12",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nMay 12, 2021\nPage 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "of 3500 Material: (1) a statement by the witness, (2) in the possession of the United States, (3)\nthat relates to the subject matter of the witness's testimony.\")",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "This case now involves a ten-year time period beginning 27 years ago. The indictment\nand the accusers are vague regarding when things happened, what things happened and who may\nhave been present when anything is alleged to have happened. Accuser-2's journal contains\ndated entries that place events in context with other alleged events. Accuser-2's journal from\n1996 purports to document encounters with Epstein in New York. The S2 indictment, paragraph\n9(b), claims that “Maxwell interacted with [Accuser-2] on at least one occasion in or about 1996\nat Epstein's residence in New Mexico….” The journal references other dates, places, and events\nin 1996. The absence of any mention of Ms. Maxwell in context with other recorded events is\nboth relevant and exculpatory.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As a piece of physical evidence, the journal is subject to inspection and testing. See F. R.\nCrim. P. 17(c)(1). Moreover, were the journal in the possession of the government it would be\nsubject to inspection under F. R. Crim. P. 16 (a) (1) (E) which provides, in relevant part:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Upon a defendant's request, the government must permit the defendant to\ninspect and to copy or photograph books, papers, documents, data,\nphotographs, tangible objects, buildings or places, or copies or portions of\nany of these items, if the item is within the government's possession,\ncustody, or control and:\n(i) the item is material to preparing the defense;\n(ii) the government intends to use the item in its case-in-chief at trial[.]\nTo avoid any disclosure obligations, the government has simply accepted partisan\nphotocopies of five substantive pages without questioning the provenance of an exhibit it intends\nto introduce at trial. Comparison of one of the five pages demonstrates the problem. Attached as\nexhibit A is a photocopy of a journal entry first produced during the civil litigation. A photocopy",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011246",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Epstein",
      "Maxwell",
      "Accuser-2"
    ],
    "organizations": [
      "United States Department of Justice"
    ],
    "locations": [
      "New York",
      "New Mexico"
    ],
    "dates": [
      "May 12, 2021",
      "07/12/22",
      "1996"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 705",
      "DOJ-OGR-00011246"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of United States v. Maxwell. The text is printed and legible, with no visible handwriting or stamps. The document is page 6 of a 12-page filing."
}