mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00005036.json

{
  "document_metadata": {
    "page_number": "7",
    "document_number": "334",
    "date": "08/13/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page 7 of 10 to justify the relevance of that evidence; she does not claim, for instance, that that evidence is exculpatory or that the evidence is otherwise relevant to her defense. Furthermore, Maxwell does not attempt to justify the relevance of all of the requested materials. The very nature of the request evinces that it seeks considerable amounts of physical evidence, and the only thing tying the evidence together is that Subpoena Recipient-2 may have shown that evidence to certain attorneys at some point. To prevail under Nixon, however, a movant must show why all of the requested evidence is relevant. United States v. Pena, No. 15-CR-551 (AJN), 2016 WL 8735699, at *2 (S.D.N.Y. Feb. 12, 2016). That is not the case here. The request thus fails because Maxwell has not established the relevance of all of these materials. The most she can muster is that some of it may be relevant for impeachment purposes, if Subpoena Recipient-2 is called to testify. On that basis alone, the request fails. In addition, the third request separately fails because it amounts to nothing more than a fishing expedition. See Nixon, 418 U.S. at 698–700. As a result, the request for authorization of a Rule 17(c) subpoena to Subpoena Recipient-2 is DENIED. C. Subpoena Recipient-3 and Subpoena Recipient-4 The final two requests for authorization of Rule 17(c) subpoenas—one relating to Subpoena Recipient-3, the other to Subpoena Recipient-4—are the same. The first five requests in both of these proposed subpoenas concern communications regarding meetings with the United States Attorney’s Office for the Southern District of New York. These requests parallel those that Maxwell made in the proposed subpoena to BSF. See Dkt. No. 252, April 27, 2021 Op., at 3–4. As set forth in the subpoenas, the term “communications” encompasses “all forms of correspondence, including regular mail, email, text message, memorandum, or other written 7 DOJ-OGR-00005036",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 334 Filed 08/13/21 Page 7 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "to justify the relevance of that evidence; she does not claim, for instance, that that evidence is exculpatory or that the evidence is otherwise relevant to her defense. Furthermore, Maxwell does not attempt to justify the relevance of all of the requested materials. The very nature of the request evinces that it seeks considerable amounts of physical evidence, and the only thing tying the evidence together is that Subpoena Recipient-2 may have shown that evidence to certain attorneys at some point. To prevail under Nixon, however, a movant must show why all of the requested evidence is relevant. United States v. Pena, No. 15-CR-551 (AJN), 2016 WL 8735699, at *2 (S.D.N.Y. Feb. 12, 2016). That is not the case here. The request thus fails because Maxwell has not established the relevance of all of these materials. The most she can muster is that some of it may be relevant for impeachment purposes, if Subpoena Recipient-2 is called to testify. On that basis alone, the request fails. In addition, the third request separately fails because it amounts to nothing more than a fishing expedition. See Nixon, 418 U.S. at 698–700. As a result, the request for authorization of a Rule 17(c) subpoena to Subpoena Recipient-2 is DENIED.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "C. Subpoena Recipient-3 and Subpoena Recipient-4 The final two requests for authorization of Rule 17(c) subpoenas—one relating to Subpoena Recipient-3, the other to Subpoena Recipient-4—are the same. The first five requests in both of these proposed subpoenas concern communications regarding meetings with the United States Attorney’s Office for the Southern District of New York. These requests parallel those that Maxwell made in the proposed subpoena to BSF. See Dkt. No. 252, April 27, 2021 Op., at 3–4. As set forth in the subpoenas, the term “communications” encompasses “all forms of correspondence, including regular mail, email, text message, memorandum, or other written",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "7",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005036",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Nixon",
      "Pena"
    ],
    "organizations": [
      "United States Attorney’s Office"
    ],
    "locations": [
      "Southern District of New York",
      "New York"
    ],
    "dates": [
      "08/13/21",
      "Feb. 12, 2016",
      "April 27, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 334",
      "15-CR-551 (AJN)",
      "Dkt. No. 252"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 7 of 10."
}