mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003838.json

{
  "document_metadata": {
    "page_number": "6",
    "document_number": "213",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 213 Filed 04/16/21 Page 6 of 8\n\nnames, but given the government's recent harbinger of a superseding indictment, likely to attempt to fix some of these problems, Ms. Maxwell is wasting time and money playing whack-a-mole with this Indictment.\n\nII. This Indictment Does Not Satisfy Minimal Notice Requirements\n\nIn Hamling v. United States, 418 U.S. 87, 117-18 (1974), the United States Supreme Court explained the circumstances in which an indictment simply setting forth the offense in the words of the statute may not suffice:\n\nOur prior cases indicate that an indictment is sufficient if it, first, contains the elements of the offense charged and fairly informs a defendant of the charge against which [s]he must defend, and, second, enables [her] to plead an acquittal or conviction in bar of future prosecutions for the same offense. It is generally sufficient that an indictment set forth the offense in the words of the statute itself, as long as those words of themselves fully, directly, and expressly, without any uncertainty or ambiguity, set forth all the elements necessary to constitute the offence intended to be punished. Undoubtedly the language of the statute may be used in the general description of an offence, but it must be accompanied with such a statement of the facts and circumstances as will inform the accused of the specific offence, coming under the general description, with which [she] is charged. (cleaned up).\n\nThe government has failed to provide an indictment that \"directly,\" \"expressly,\" and \"without uncertainty or ambiguity\" sets forth the allegations against her. The alleged facts are vague and illusory and no meaningful discovery has been provided. Accordingly, Ms. Maxwell cannot adequately defend herself, in violation of the Fifth and Sixth Amendments to the United States Constitution.\n\nCONCLUSION\n\nBecause Counts One through Four of the Indictment lack the basic factual information necessary for Ms. Maxwell to prepare her defense, and the government refuses to provide any meaningful discovery, the Court should either dismiss these counts or direct the government to answer Ms. Maxwell's requests for particularity.\n\n5\n\nDOJ-OGR-00003838",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 213 Filed 04/16/21 Page 6 of 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "names, but given the government's recent harbinger of a superseding indictment, likely to attempt to fix some of these problems, Ms. Maxwell is wasting time and money playing whack-a-mole with this Indictment.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "II. This Indictment Does Not Satisfy Minimal Notice Requirements",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In Hamling v. United States, 418 U.S. 87, 117-18 (1974), the United States Supreme Court explained the circumstances in which an indictment simply setting forth the offense in the words of the statute may not suffice:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Our prior cases indicate that an indictment is sufficient if it, first, contains the elements of the offense charged and fairly informs a defendant of the charge against which [s]he must defend, and, second, enables [her] to plead an acquittal or conviction in bar of future prosecutions for the same offense. It is generally sufficient that an indictment set forth the offense in the words of the statute itself, as long as those words of themselves fully, directly, and expressly, without any uncertainty or ambiguity, set forth all the elements necessary to constitute the offence intended to be punished. Undoubtedly the language of the statute may be used in the general description of an offence, but it must be accompanied with such a statement of the facts and circumstances as will inform the accused of the specific offence, coming under the general description, with which [she] is charged. (cleaned up).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government has failed to provide an indictment that \"directly,\" \"expressly,\" and \"without uncertainty or ambiguity\" sets forth the allegations against her. The alleged facts are vague and illusory and no meaningful discovery has been provided. Accordingly, Ms. Maxwell cannot adequately defend herself, in violation of the Fifth and Sixth Amendments to the United States Constitution.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "CONCLUSION",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Because Counts One through Four of the Indictment lack the basic factual information necessary for Ms. Maxwell to prepare her defense, and the government refuses to provide any meaningful discovery, the Court should either dismiss these counts or direct the government to answer Ms. Maxwell's requests for particularity.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003838",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "United States Supreme Court",
      "Court"
    ],
    "locations": [
      "United States"
    ],
    "dates": [
      "04/16/21",
      "1974"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 213",
      "418 U.S. 87",
      "DOJ-OGR-00003838"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is well-formatted and printed, with no visible handwriting or stamps. The document is page 6 of 8."
}