mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00004005.json

{
  "document_metadata": {
    "page_number": "5",
    "document_number": "247",
    "date": "04/23/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 247 Filed 04/23/21 Page 5 of 17\nThe Honorable Alison J. Nathan\nApril 5, 2021\nPage 5 of 17\nThe Defendant argues that Requests 1 through 5 are not a fishing expedition merely because the government has admitted \"that there were, in fact meetings and communications between these individuals and the USAO-SDNY about Ms. Maxwell and _______\" and because Virginia Giuffre logged a number of communications on a privilege log in 2016. Resp. Ltr. at 2, 3. This does not get the Requests over Nixon's hurdles—the Defendant is still attempting to fish through BSF's communications in the hopes that something relevant and admissible turns up, without setting forth the relevance and admissibility as to each document she seeks. Further the privilege log does not, as the Defendant insinuates, reference communications between BSF and the U.S. Attorney as defined in the Subpoena, as the log references only an unspecified \"law enforcement agency.\" Id. at 4.\nB. The Defendant Has Not Demonstrated Relevance and Admissibility.\nThe Court's analysis does not stop at specificity—Requests 1 through 5 independently fail because the Defendant has not demonstrated that all of the communications she seeks are relevant and admissible. The Defendant's sole basis for contending that the wide array of communications she seeks are all relevant to her defense is that the communications are relevant to \"two motions to suppress based on misrepresentations made by the government to Chief Judge McMahon and a motion to dismiss the indictment for prejudicial delay\" because they \"would establish the substance and frequency of the communications between BSF and the government prior to the government's end run around Martindell.\" Resp. Ltr. at 6–7. But the Defendant has not met her burden of demonstrating relevance and admissibility.\nFirst, because Rule 17's \"purpose is trial-focused,\" a Rule 17(c) subpoena \"may be used only to obtain materials admissible as evidence at trial.\" United States v. Louis, No. 04 Cr. 203 (LTS), 2005 WL 180885, at *3 (S.D.N.Y. Jan. 27, 2005) (emphasis added); see also United States\nDOJ-OGR-00004005",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 247 Filed 04/23/21 Page 5 of 17",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nApril 5, 2021\nPage 5 of 17",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Defendant argues that Requests 1 through 5 are not a fishing expedition merely because the government has admitted \"that there were, in fact meetings and communications between these individuals and the USAO-SDNY about Ms. Maxwell and _______\" and because Virginia Giuffre logged a number of communications on a privilege log in 2016. Resp. Ltr. at 2, 3. This does not get the Requests over Nixon's hurdles—the Defendant is still attempting to fish through BSF's communications in the hopes that something relevant and admissible turns up, without setting forth the relevance and admissibility as to each document she seeks. Further the privilege log does not, as the Defendant insinuates, reference communications between BSF and the U.S. Attorney as defined in the Subpoena, as the log references only an unspecified \"law enforcement agency.\" Id. at 4.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "B. The Defendant Has Not Demonstrated Relevance and Admissibility.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The Court's analysis does not stop at specificity—Requests 1 through 5 independently fail because the Defendant has not demonstrated that all of the communications she seeks are relevant and admissible. The Defendant's sole basis for contending that the wide array of communications she seeks are all relevant to her defense is that the communications are relevant to \"two motions to suppress based on misrepresentations made by the government to Chief Judge McMahon and a motion to dismiss the indictment for prejudicial delay\" because they \"would establish the substance and frequency of the communications between BSF and the government prior to the government's end run around Martindell.\" Resp. Ltr. at 6–7. But the Defendant has not met her burden of demonstrating relevance and admissibility.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "First, because Rule 17's \"purpose is trial-focused,\" a Rule 17(c) subpoena \"may be used only to obtain materials admissible as evidence at trial.\" United States v. Louis, No. 04 Cr. 203 (LTS), 2005 WL 180885, at *3 (S.D.N.Y. Jan. 27, 2005) (emphasis added); see also United States",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004005",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Virginia Giuffre",
      "Chief Judge McMahon",
      "Louis"
    ],
    "organizations": [
      "USAO-SDNY",
      "BSF",
      "U.S. Attorney",
      "DOJ"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "April 5, 2021",
      "04/23/21",
      "Jan. 27, 2005",
      "2016"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 247",
      "No. 04 Cr. 203 (LTS)",
      "2005 WL 180885"
    ]
  },
  "additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage to the document."
}