mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011369.json

{
  "document_metadata": {
    "page_number": "7",
    "document_number": "723",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 723 Filed 07/12/22 Page 7 of 13\nThe Honorable Alison J. Nathan\nDecember 16, 2021\nPage 7\n\nMs. Maxwell has a right to present the testimony of Eva, who will deny Jane's allegations of being involved in the group sexualized massages that are the basis of the charges in this case.\n\nB. Micchell Healy's testimony will contradict Jane's testimony.\nMichelle's testimony will also contradict Jane's testimony. As to Michelle, this is what Jane testified to on the stand:\n- There was a fourth woman Jane remembers, named Michelle, who was short. TR at 526.\n- Jane hung out with Michelle and Emmy and sometimes went out with Michelle and Emmy. Id. at 527.2\n- Michelle \"was also involved in the sexual contact.\" Id.\n- Michelle was also involved in \"group massages.\" Id.\n\nThe government did not examine Jane on any of these points, and it did not ask Jane whether Michelle was only involved in group massages with Mr. Epstein after Jane attained the age of 17.3 Nor did the government ask Jane during its interviews when Michelle was involved\n\n2 The government's letter conveniently omits this testimony from Jane, which, as described below, establishes that Michelle Healy is the Michelle who Jane alleged was involved in group sexualized massages.\n\n3 The government's attempt to bootstrap Rule 412 into its motion fails. Gov. Letter, p 7. In her interview with the government, Jane said she was involved with sexualized massages with Michelle in New York when she was \"young.\" See 3509-001, p 4. Even if, based on Jane's trial testimony, one might infer she was 17 years old at the time of the sexualized massages with Michelle, she said something different in her interviews with the government. And in any event, because the sexualized massages are the very conduct at issue in this case and are not collateral, Ms. Maxwell does not have to accept Jane's trial testimony as the last word on the issue. \"The law of evidence has long recognized that a cross-examiner is not required to 'take the answer'\" of a witness on a non-collateral issue, United States v. Harvey, 547 F.2d 720, 722 (2d Cir. 1976), such as her allegations about the very conduct she says is criminal.\n\nDOJ-OGR-00011369",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 723 Filed 07/12/22 Page 7 of 13",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nDecember 16, 2021\nPage 7",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell has a right to present the testimony of Eva, who will deny Jane's allegations of being involved in the group sexualized massages that are the basis of the charges in this case.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "B. Micchell Healy's testimony will contradict Jane's testimony.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Michelle's testimony will also contradict Jane's testimony. As to Michelle, this is what Jane testified to on the stand:\n- There was a fourth woman Jane remembers, named Michelle, who was short. TR at 526.\n- Jane hung out with Michelle and Emmy and sometimes went out with Michelle and Emmy. Id. at 527.2\n- Michelle \"was also involved in the sexual contact.\" Id.\n- Michelle was also involved in \"group massages.\" Id.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government did not examine Jane on any of these points, and it did not ask Jane whether Michelle was only involved in group massages with Mr. Epstein after Jane attained the age of 17.3 Nor did the government ask Jane during its interviews when Michelle was involved",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2 The government's letter conveniently omits this testimony from Jane, which, as described below, establishes that Michelle Healy is the Michelle who Jane alleged was involved in group sexualized massages.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3 The government's attempt to bootstrap Rule 412 into its motion fails. Gov. Letter, p 7. In her interview with the government, Jane said she was involved with sexualized massages with Michelle in New York when she was \"young.\" See 3509-001, p 4. Even if, based on Jane's trial testimony, one might infer she was 17 years old at the time of the sexualized massages with Michelle, she said something different in her interviews with the government. And in any event, because the sexualized massages are the very conduct at issue in this case and are not collateral, Ms. Maxwell does not have to accept Jane's trial testimony as the last word on the issue. \"The law of evidence has long recognized that a cross-examiner is not required to 'take the answer'\" of a witness on a non-collateral issue, United States v. Harvey, 547 F.2d 720, 722 (2d Cir. 1976), such as her allegations about the very conduct she says is criminal.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011369",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell",
      "Eva",
      "Jane",
      "Michelle Healy",
      "Emmy",
      "Mr. Epstein"
    ],
    "organizations": [],
    "locations": [
      "New York"
    ],
    "dates": [
      "December 16, 2021",
      "07/12/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 723",
      "TR at 526",
      "Id. at 527",
      "3509-001, p 4",
      "547 F.2d 720, 722 (2d Cir. 1976)",
      "DOJ-OGR-00011369"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document quality is clear and legible."
}