mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006194.json

{
  "document_metadata": {
    "page_number": "14",
    "document_number": "418-1",
    "date": "11/08/21",
    "document_type": "court document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 418-1 Filed 11/08/21 Page 14 of 14\nComey, Moe, Pomerantz and Rohrbach\nNovember 1, 2021\nPage 14\n\nH. Jennifer Naso\n\nMs. Naso is a Forensic Document Examiner who worked for and received specialized training from the United States Secret Service as a Document Analyst. Ms. Naso has a Master's of Science in Forensic Science and a Bachelor of Arts in Psychology. She has over 15 years of experience examining and determining authorship and authentication of documents. Her curriculum vitae is attached as Exhibit K.\n\nDefendant anticipates the receipt of documents produced by the government and pursuant to defense subpoena included but not limited to . These documents may require analysis regarding the dates of creation, completeness, alteration and manipulation. When these documents are disclosed, Defendant will seek to have them analyzed and present testimony on the analysis as needed.\n\nII. RESERVATION OF RIGHTS\n\nThe defense reserves the right to amplify the disclosures contained herein based on testimony and other evidence presented during the government's case-in-chief. The defense also reserves the right to call additional expert witnesses and will promptly provide additional disclosure notice.\n\nIII. RIGHT TO SUPPLEMENT\n\nMs. Maxwell reserves the right to supplement these opinions depending on the evidence produced at trial. To the extent that any accuser claims to have been \"groomed\" or otherwise testifies to the challenged opinions of Dr. Rocchio or other opinions properly rebutted by expert testimony Ms. Maxwell reserves the right to identify and rebut this testimony after the close of the government's case in chief.\n\nVery Truly Yours,\n\nJeffrey S. Pagliuca\n\nEnclosures",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 418-1 Filed 11/08/21 Page 14 of 14",
      "position": "header"
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    {
      "type": "printed",
      "content": "Comey, Moe, Pomerantz and Rohrbach\nNovember 1, 2021\nPage 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "H. Jennifer Naso",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Ms. Naso is a Forensic Document Examiner who worked for and received specialized training from the United States Secret Service as a Document Analyst. Ms. Naso has a Master's of Science in Forensic Science and a Bachelor of Arts in Psychology. She has over 15 years of experience examining and determining authorship and authentication of documents. Her curriculum vitae is attached as Exhibit K.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Defendant anticipates the receipt of documents produced by the government and pursuant to defense subpoena included but not limited to . These documents may require analysis regarding the dates of creation, completeness, alteration and manipulation. When these documents are disclosed, Defendant will seek to have them analyzed and present testimony on the analysis as needed.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "II. RESERVATION OF RIGHTS",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defense reserves the right to amplify the disclosures contained herein based on testimony and other evidence presented during the government's case-in-chief. The defense also reserves the right to call additional expert witnesses and will promptly provide additional disclosure notice.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "III. RIGHT TO SUPPLEMENT",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell reserves the right to supplement these opinions depending on the evidence produced at trial. To the extent that any accuser claims to have been \"groomed\" or otherwise testifies to the challenged opinions of Dr. Rocchio or other opinions properly rebutted by expert testimony Ms. Maxwell reserves the right to identify and rebut this testimony after the close of the government's case in chief.",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Jeffrey S. Pagliuca",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "Very Truly Yours,",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "Enclosures",
      "position": "bottom"
    }
  ],
  "entities": {
    "people": [
      "Jennifer Naso",
      "Jeffrey S. Pagliuca",
      "Ms. Maxwell",
      "Dr. Rocchio"
    ],
    "organizations": [
      "United States Secret Service"
    ],
    "locations": [],
    "dates": [
      "November 1, 2021",
      "11/08/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "418-1"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a signature and enclosures. There is a redacted section in the text."
}