mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011310.json

{
  "document_metadata": {
    "page_number": "7",
    "document_number": "714",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 714 Filed 07/12/22 Page 7 of 7\nlaw, avoids incorrectly suggesting that the entirety of the witness's testimony will describe events that took place after the witness reached the age of consent, and avoids prejudice to the Government from an unbalanced instruction. In the Government's view, however, any concern that jurors will mistakenly think they should convict on the basis of some violation of another state's laws is best addressed in the concluding jury instructions. Such instructions will make the most sense to the jurors once they have heard all the facts and been instructed regarding the elements of each offense charged in the Indictment.\nRespectfully submitted,\nDAMIAN WILLIAMS\nUnited States Attorney\nBy: s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\nCc: Defense Counsel (by e-mail)\nDOJ-OGR-00011310",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 714 Filed 07/12/22 Page 7 of 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "law, avoids incorrectly suggesting that the entirety of the witness's testimony will describe events that took place after the witness reached the age of consent, and avoids prejudice to the Government from an unbalanced instruction. In the Government's view, however, any concern that jurors will mistakenly think they should convict on the basis of some violation of another state's laws is best addressed in the concluding jury instructions. Such instructions will make the most sense to the jurors once they have heard all the facts and been instructed regarding the elements of each offense charged in the Indictment.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,\nDAMIAN WILLIAMS\nUnited States Attorney\nBy: s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Cc: Defense Counsel (by e-mail)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011310",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Damian Williams",
      "Maurene Comey",
      "Alison Moe",
      "Lara Pomerantz",
      "Andrew Rohrbach"
    ],
    "organizations": [
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "07/12/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "714",
      "DOJ-OGR-00011310"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage."
}