mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008108.json

{
  "document_metadata": {
    "page_number": "23",
    "document_number": "508",
    "date": "11/24/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 508 Filed 11/24/21 Page 23 of 25\n\nIII. This Court Should Reject the Government's Remaining Arguments.\n\nThe government objects to the adequacy of the notice Ms. Maxwell has provided with regard to Robert Kelso, John Lopez, Gerald LaPorte, and Jennifer Naso. Mot. at 21-26. Really only two responses are in order.\n\nMs. Maxwell's notices are as thorough as the government's notices were, so the government can hardly complain about being in the dark. But if this Court concludes otherwise, the remedy is for Ms. Maxwell to provide additional notice; the remedy is not exclusion.\n\nMoreover, as the government concedes is permissible, Ms. Maxwell has endorsed these witnesses in part out of an abundance of caution and in part because Ms. Maxwell still doesn't know what evidence the government will actually admit at trial. If testimony from these witnesses is not relevant, Ms. Maxwell will not call them. But if the government's evidence makes their testimony relevant, Ms. Maxwell can always provide additional notice if ordered to do so by the Court.\n\nCONCLUSION\n\nThis Court should deny the government's motion.\n\nDated: November 19, 2021\n\n19\nDOJ-OGR-00008108",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 508 Filed 11/24/21 Page 23 of 25",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "III. This Court Should Reject the Government's Remaining Arguments.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The government objects to the adequacy of the notice Ms. Maxwell has provided with regard to Robert Kelso, John Lopez, Gerald LaPorte, and Jennifer Naso. Mot. at 21-26. Really only two responses are in order.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell's notices are as thorough as the government's notices were, so the government can hardly complain about being in the dark. But if this Court concludes otherwise, the remedy is for Ms. Maxwell to provide additional notice; the remedy is not exclusion.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Moreover, as the government concedes is permissible, Ms. Maxwell has endorsed these witnesses in part out of an abundance of caution and in part because Ms. Maxwell still doesn't know what evidence the government will actually admit at trial. If testimony from these witnesses is not relevant, Ms. Maxwell will not call them. But if the government's evidence makes their testimony relevant, Ms. Maxwell can always provide additional notice if ordered to do so by the Court.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "CONCLUSION",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "This Court should deny the government's motion.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dated: November 19, 2021",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "19",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008108",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Robert Kelso",
      "John Lopez",
      "Gerald LaPorte",
      "Jennifer Naso",
      "Ms. Maxwell"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "November 19, 2021",
      "11/24/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "508",
      "DOJ-OGR-00008108"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage."
}