mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006045.json

{
  "document_metadata": {
    "page_number": "3",
    "document_number": "406",
    "date": "11/02/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 406 Filed 11/02/21 Page 3 of 6\n\nPage 3\n\ncredibility will be the central question for the jury in this case.\" (Dkt. No. 291 at 12). From the face of the expert notice, it appears that few if any of the defendant's eight experts would offer testimony whose relevance only became apparent after the Government's production of Jencks Act material and its exhibit list, and it is unlikely that these eight experts were all retained in the last two weeks. The Government should not now be prejudiced by the defendant's apparent gamesmanship in seeking an unnecessarily cramped disclosure schedule. Accordingly, for these six experts, the Government proposes to submit any Daubert briefing on November 23, with defense responses due November 30.\n\nDefense Position\n\nMs. Maxwell requests that the Court hold the hearing on November 10, 2021.\n\nThe Court gave the parties a simple directive which was to confer and pick a date for the Daubert and Rule 412 hearing, the options being November 5, 9, or 10. Defense counsel attempted this conferral and sent an email to the government stating, in relevant part:\n\n[W]e are free for the Rule 412/Daubert hearing on Nov. 9 or 10 but have a preference for Nov. 10. Please advise what the government's preference is.\n\nI believe the Court requested that we give our preference about the date of the Rule 412/Daubert hearing in a joint letter to the Court filed on ECF. I think we could include our positions on the trial length in that letter as well. Please let me know if you will draft the letter or if you would like the defense to draft it.\n\nThe government's non-response to this straightforward conferral was: \"On the timing of the 412/Daubert hearing, we're preparing a draft letter which we'll send you shortly.\"\n\nInstead of conferring with defense counsel the government at, 7:07 p.m., sent its two sentence non-conferral:\n\nOn the other issue, scheduling the Daubert/412 hearing, attached is a draft letter, along with our proposed redactions to your expert notice. Please feel free to insert your position, which we ask that you do by 9:00.\n\nDOJ-OGR-00006045",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 406 Filed 11/02/21 Page 3 of 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "credibility will be the central question for the jury in this case.\" (Dkt. No. 291 at 12). From the face of the expert notice, it appears that few if any of the defendant's eight experts would offer testimony whose relevance only became apparent after the Government's production of Jencks Act material and its exhibit list, and it is unlikely that these eight experts were all retained in the last two weeks. The Government should not now be prejudiced by the defendant's apparent gamesmanship in seeking an unnecessarily cramped disclosure schedule. Accordingly, for these six experts, the Government proposes to submit any Daubert briefing on November 23, with defense responses due November 30.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Defense Position",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell requests that the Court hold the hearing on November 10, 2021.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The Court gave the parties a simple directive which was to confer and pick a date for the Daubert and Rule 412 hearing, the options being November 5, 9, or 10. Defense counsel attempted this conferral and sent an email to the government stating, in relevant part:\n\n[W]e are free for the Rule 412/Daubert hearing on Nov. 9 or 10 but have a preference for Nov. 10. Please advise what the government's preference is.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "I believe the Court requested that we give our preference about the date of the Rule 412/Daubert hearing in a joint letter to the Court filed on ECF. I think we could include our positions on the trial length in that letter as well. Please let me know if you will draft the letter or if you would like the defense to draft it.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The government's non-response to this straightforward conferral was: \"On the timing of the 412/Daubert hearing, we're preparing a draft letter which we'll send you shortly.\"",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Instead of conferring with defense counsel the government at, 7:07 p.m., sent its two sentence non-conferral:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "On the other issue, scheduling the Daubert/412 hearing, attached is a draft letter, along with our proposed redactions to your expert notice. Please feel free to insert your position, which we ask that you do by 9:00.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006045",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [],
    "dates": [
      "November 10, 2021",
      "November 5",
      "November 9",
      "November 10",
      "November 23",
      "November 30"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 406",
      "Dkt. No. 291"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}