mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006480.json

{
  "document_metadata": {
    "page_number": "63",
    "document_number": "439",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 439 Filed 11/12/21 Page 63 of 69\n\nThe parties should follow the Rules. Ms. Maxwell intends to do so and will object to evidence she believes is inadmissible at trial.\n\nIX. MS. MAXWELL'S COUNSEL UNDERSTANDS AND WILL FOLLOW THE RULES OF EVIDENCE AND PROHIBITION AGAINST ARGUMENT FOR JURY NULLIFICATION - RENDERING THIS MOTION MOOT\n\nThis motion in limine, like most of the preceding ones, is another request that the parties, and the Court, abide by the Federal Rules of Evidence or that the Court offer an advisory opinion as to which types of evidence fall within the Rules. As described previously, supra at Preliminary Statement, these are inappropriate motions in limine. It is unclear if the government's real intent in filing the motion is to entice defense counsel to share her intended evidence or arguments for trial in advance of the deadlines set by this Court. In any event, Ms. Maxwell's defense and her evidence depends very much on what evidence the government elicits or argues at trial and in opening statements.\n\nThere are certain longstanding and easily understood rules of evidence which apply to this case. Rule 404(a)(2) permits introduction at trial of a defendant's \"pertinent trait,\" which, if offered, the government may rebut. Rule 405(a) permits evidence of a person's character or character trait by reputation or opinion, which, if offered, the opposing party may then inquire as to relevant specific instances of conduct. Rule 608(a) permits a witness's credibility to be attacked or supported by reputation testimony for truthfulness or untruthfulness. Ms. Maxwell and her counsel do not dispute that these rules of evidence apply nor that they all understand the prohibitions on encouraging jury nullification. Ms. Maxwell and her counsel will not argue to the jury that they may acquit if they do not like that law. See United States v. Gardner, No. 16-cr-20135, 2016 WL 5404207, at *6-*7 (E.D. Mich. Sept. 28, 2016) (denying motion in limine regarding jury nullification. because, \"[a]t this point, it is unclear exactly what is included in the category of \"evidence or argument that relates only to jury nullification. Although some\n\n55\n\nDOJ-OGR-00006480",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 439 Filed 11/12/21 Page 63 of 69",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The parties should follow the Rules. Ms. Maxwell intends to do so and will object to evidence she believes is inadmissible at trial.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "IX. MS. MAXWELL'S COUNSEL UNDERSTANDS AND WILL FOLLOW THE RULES OF EVIDENCE AND PROHIBITION AGAINST ARGUMENT FOR JURY NULLIFICATION - RENDERING THIS MOTION MOOT",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "This motion in limine, like most of the preceding ones, is another request that the parties, and the Court, abide by the Federal Rules of Evidence or that the Court offer an advisory opinion as to which types of evidence fall within the Rules. As described previously, supra at Preliminary Statement, these are inappropriate motions in limine. It is unclear if the government's real intent in filing the motion is to entice defense counsel to share her intended evidence or arguments for trial in advance of the deadlines set by this Court. In any event, Ms. Maxwell's defense and her evidence depends very much on what evidence the government elicits or argues at trial and in opening statements.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "There are certain longstanding and easily understood rules of evidence which apply to this case. Rule 404(a)(2) permits introduction at trial of a defendant's \"pertinent trait,\" which, if offered, the government may rebut. Rule 405(a) permits evidence of a person's character or character trait by reputation or opinion, which, if offered, the opposing party may then inquire as to relevant specific instances of conduct. Rule 608(a) permits a witness's credibility to be attacked or supported by reputation testimony for truthfulness or untruthfulness. Ms. Maxwell and her counsel do not dispute that these rules of evidence apply nor that they all understand the prohibitions on encouraging jury nullification. Ms. Maxwell and her counsel will not argue to the jury that they may acquit if they do not like that law. See United States v. Gardner, No. 16-cr-20135, 2016 WL 5404207, at *6-*7 (E.D. Mich. Sept. 28, 2016) (denying motion in limine regarding jury nullification. because, \"[a]t this point, it is unclear exactly what is included in the category of \"evidence or argument that relates only to jury nullification. Although some",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "55",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006480",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "Court"
    ],
    "locations": [
      "E.D. Mich."
    ],
    "dates": [
      "11/12/21",
      "Sept. 28, 2016"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 439",
      "16-cr-20135"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is mostly printed, with no visible handwriting or stamps. The document is page 63 of 69."
}