mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00008199.json

{
  "document_metadata": {
    "page_number": "6",
    "document_number": "518",
    "date": "November 30, 2021",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 518 Filed 11/30/21 Page 6 of 8\nThe Honorable Alison J. Nathan\nNovember 30, 2021\nPage 6\nHere, there is no prejudice, and the government did not attempt to identify any.\nMoreover, any conceivable prejudice can be remedied by giving the government additional time to review the photograph before Ms. Maxwell again offers it into evidence. See, e.g., United States v. Kessler, 926 F.3d 490, 491 (8th Cir. 2019) (concluding that court was correct not to exclude government's evidence of \"the dollar value of the methamphetamine,\" despite Rule 16 violation, because the court \"provided a one-hour recess that allowed defense counsel to prepare a response\").3\nThe government's interpretation of Rule 16, if accepted, would violate Ms. Maxwell's constitutional rights to due process and the confrontation. U.S. Const. amends. V, VI.\nCompelling Ms. Maxwell to disclose to the prosecution, in advance, evidence she intends to use to impeach government witnesses during the government's case-in-chief would unconstitutionally force her to aid the government in meeting its burden of proof. U.S. Const. amend. V. See People v. Kilgore, 455 P.3d 746, 751 (Colo. 2020) (compelling the defendant to disclose his intended exhibits, \"at a minimum, potentially infringed on [his] right to due process because his compliance with the disclosure order may help the prosecution meet its burden of proof\"). And it would compromise her constitutional right to confront the witnesses against her, a right she is free to exercise without previewing her defense for the government. U.S. Const. amend. VI.\n3 Of course, come tomorrow, the government will have had more than twelve hours to review the photograph.\nDOJ-OGR-00008199",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 518 Filed 11/30/21 Page 6 of 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nNovember 30, 2021\nPage 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Here, there is no prejudice, and the government did not attempt to identify any.\nMoreover, any conceivable prejudice can be remedied by giving the government additional time to review the photograph before Ms. Maxwell again offers it into evidence. See, e.g., United States v. Kessler, 926 F.3d 490, 491 (8th Cir. 2019) (concluding that court was correct not to exclude government's evidence of \"the dollar value of the methamphetamine,\" despite Rule 16 violation, because the court \"provided a one-hour recess that allowed defense counsel to prepare a response\").3",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The government's interpretation of Rule 16, if accepted, would violate Ms. Maxwell's constitutional rights to due process and the confrontation. U.S. Const. amends. V, VI.\nCompelling Ms. Maxwell to disclose to the prosecution, in advance, evidence she intends to use to impeach government witnesses during the government's case-in-chief would unconstitutionally force her to aid the government in meeting its burden of proof. U.S. Const. amend. V. See People v. Kilgore, 455 P.3d 746, 751 (Colo. 2020) (compelling the defendant to disclose his intended exhibits, \"at a minimum, potentially infringed on [his] right to due process because his compliance with the disclosure order may help the prosecution meet its burden of proof\"). And it would compromise her constitutional right to confront the witnesses against her, a right she is free to exercise without previewing her defense for the government. U.S. Const. amend. VI.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "3 Of course, come tomorrow, the government will have had more than twelve hours to review the photograph.",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008199",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "November 30, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 518",
      "DOJ-OGR-00008199"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 6 of 8."
}