mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011248.json

{
  "document_metadata": {
    "page_number": "8",
    "document_number": "705",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 705 Filed 07/12/22 Page 8 of 12\nThe Honorable Alison J. Nathan\nMay 12, 2021\nPage 8\n(Dkt. 271, p.1) Tripping over its own largess, the “Prosecution Team” neglected to mention that\nMs. Maxwell and her lawyers traveled to New York to review all of the physical evidence,\nincluding original photographs, in person, at considerable expense from April 12 to April 16,\n2021. The government does not explain which original photographs it has in its possession nor\ndoes it offer any reason why these photographs were not made available “upon request.”\nAttempts to confer with the government to explain these discrepancies have gone unanswered for\ndays.\nPhotocopies, in most cases, (and most certainly in this case) are not adequate substitutes\nfor originals, particularly when the photocopies are produced by lawyers adverse to Ms.\nMaxwell, were not collected by law enforcement directly from the source, and are subject to\nmanipulation. Any original photographs will have markings that identify when the film was\ndeveloped and other indicia indicating whether they are genuine or not. Again, like the journal,\nthe government has outsourced the fact and truth finding function regarding the photographs to\npartisan advocates. If the government possessed the originals Ms. Maxwell would have the Rule\n16 right to inspect them, just like the many photographs she inspected between April 12 and\nApril 16, 2021.\nFinally, the government devotes much of its submission attempting to bait Ms. Maxwell\ninto revealing defense strategy and work product. Ms. Maxwell is happy to address any questions\nregarding relevance and admissibility ex-parte should the Court need any additional information.\nRespectfully Submitted,\nJeffrey S. Pagliuca\nCC: Counsel of Record (via ECF)\nDOJ-OGR-00011248",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 705 Filed 07/12/22 Page 8 of 12",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nMay 12, 2021\nPage 8",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "(Dkt. 271, p.1) Tripping over its own largess, the “Prosecution Team” neglected to mention that\nMs. Maxwell and her lawyers traveled to New York to review all of the physical evidence,\nincluding original photographs, in person, at considerable expense from April 12 to April 16,\n2021. The government does not explain which original photographs it has in its possession nor\ndoes it offer any reason why these photographs were not made available “upon request.”\nAttempts to confer with the government to explain these discrepancies have gone unanswered for\ndays.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Photocopies, in most cases, (and most certainly in this case) are not adequate substitutes\nfor originals, particularly when the photocopies are produced by lawyers adverse to Ms.\nMaxwell, were not collected by law enforcement directly from the source, and are subject to\nmanipulation. Any original photographs will have markings that identify when the film was\ndeveloped and other indicia indicating whether they are genuine or not. Again, like the journal,\nthe government has outsourced the fact and truth finding function regarding the photographs to\npartisan advocates. If the government possessed the originals Ms. Maxwell would have the Rule\n16 right to inspect them, just like the many photographs she inspected between April 12 and\nApril 16, 2021.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, the government devotes much of its submission attempting to bait Ms. Maxwell\ninto revealing defense strategy and work product. Ms. Maxwell is happy to address any questions\nregarding relevance and admissibility ex-parte should the Court need any additional information.",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Jeffrey S. Pagliuca",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "Respectfully Submitted,\nJeffrey S. Pagliuca\nCC: Counsel of Record (via ECF)",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011248",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell",
      "Jeffrey S. Pagliuca"
    ],
    "organizations": [],
    "locations": [
      "New York"
    ],
    "dates": [
      "May 12, 2021",
      "April 12",
      "April 16, 2021",
      "07/12/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 705",
      "Dkt. 271",
      "Rule 16",
      "DOJ-OGR-00011248"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a signature and a reference number at the bottom. The text is mostly printed, with a handwritten signature."
}