mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00007431.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "493",
    "date": "11/22/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 493 Filed 11/22/21 Page 1 of 6\nU.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nNovember 7, 2021\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe Government respectfully submits this letter in response to the Court's order directing the Government to state its position as to whether Minor Victim-3 \"could be deemed a victim of any of the crimes charged in the indictment for any legal purposes, including for purposes of restitution under 18 U.S.C. § 3663(a)(2).\" The answer is yes. Minor Victim-3 suffered unwanted and traumatic sexual contact with Jeffrey Epstein when she was 17 years old. In addition to making her a victim in the ordinary sense of that word, it makes her a victim of the charged Mann Act conspiracies for at least the following provisions of federal law: the Crime Victim's Rights Act (\"CVRA\"), 18 U.S.C. § 3771; the Victim and Witness Protection Act (\"VWPA\"), 18 U.S.C. § 3663; and Federal Rule of Evidence 412.1\nBoth the CVRA and VWPA contain statutory definitions of the term \"victim.\" The CVRA defines \"victim\" as \"a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia.\" 18 U.S.C. § 3771(e)(2)(A). The VWPA similarly defines \"victim\" to mean \"a person directly and proximately harmed by the commission of the offense.\"1\nGiven the expedited briefing deadline, the Government has not addressed every provision of federal law that references victims, but would be happy to address any additional provisions the Court deems relevant.\nDOJ-OGR-00007431",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 493 Filed 11/22/21 Page 1 of 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "November 7, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter in response to the Court's order directing the Government to state its position as to whether Minor Victim-3 \"could be deemed a victim of any of the crimes charged in the indictment for any legal purposes, including for purposes of restitution under 18 U.S.C. § 3663(a)(2).\" The answer is yes. Minor Victim-3 suffered unwanted and traumatic sexual contact with Jeffrey Epstein when she was 17 years old. In addition to making her a victim in the ordinary sense of that word, it makes her a victim of the charged Mann Act conspiracies for at least the following provisions of federal law: the Crime Victim's Rights Act (\"CVRA\"), 18 U.S.C. § 3771; the Victim and Witness Protection Act (\"VWPA\"), 18 U.S.C. § 3663; and Federal Rule of Evidence 412.1",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Both the CVRA and VWPA contain statutory definitions of the term \"victim.\" The CVRA defines \"victim\" as \"a person directly and proximately harmed as a result of the commission of a Federal offense or an offense in the District of Columbia.\" 18 U.S.C. § 3771(e)(2)(A). The VWPA similarly defines \"victim\" to mean \"a person directly and proximately harmed by the commission of the offense.\"1",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Given the expedited briefing deadline, the Government has not addressed every provision of federal law that references victims, but would be happy to address any additional provisions the Court deems relevant.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00007431",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Jeffrey Epstein"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "United States District Court"
    ],
    "locations": [
      "New York",
      "District of Columbia"
    ],
    "dates": [
      "November 7, 2021",
      "11/22/21"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00007431"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Honorable Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The document is typed and contains legal terminology and references to specific laws and regulations."
}