mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00004045.json

{
  "document_metadata": {
    "page_number": "7",
    "document_number": "252",
    "date": "04/27/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 252 Filed 04/27/21 Page 7 of 9\n\nSee United States v. Aguilar, No. CR 07-00030 (SBA), 2008 WL 3182029, at *6 (N.D. Cal. Aug. 4, 2008). Maxwell argues that the materials are relevant because they may reveal monetary incentives to testify in a particular way. That argument demonstrates that the documents are being sought for impeachment. As stated above, the mere fact that certain documents might be impeachment evidence does not render them \"relevant\" for purposes of Rule 17(c); if at all, those documents would become relevant only after a witness testifies. See Skelos, 2018 WL 2254538, at *2. Maxwell's argument that the documents are relevant because their impeachment value is exculpatory does not get around this general bar. These materials only become relevant if or when those witnesses testify. She presents no other nonconclusory basis as to why they are exculpatory. Indeed, Maxwell concedes that the primary purpose of these documents will be for purposes of cross-examination, leaving little doubt as to the purported claim of relevance. And to the extent Maxwell posits that statements made as part of the EVCP process may be exculpatory in themselves, the argument is speculative because she provides no basis for why that expectation might be reasonable. The \"mere hope\" that the documents may contain some exculpatory evidence is insufficient to justify enforcement of a Rule 17(c) subpoena (or, as here, issuance of such a subpoena in the face of objections). See United States v. Rich, No. S 83-CR-579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984). Maxwell's reliance on cases involving the Government's obligations under Brady and Giglio to produce impeachment evidence prior to trial are thus inapposite to the current context. Pena, 2016 WL 8735699, at *2-3. Maxwell thus fails to establish Request 12's compliance with the Nixon standards. Maxwell may renew her request for these documents once she identifies specific individuals whose submissions she seeks and spells out with specificity the relevance of all requested materials. At that time, the Court will determine whether it is proper to require production of these materials to 7\n\nDOJ-OGR-00004045",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 252 Filed 04/27/21 Page 7 of 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "See United States v. Aguilar, No. CR 07-00030 (SBA), 2008 WL 3182029, at *6 (N.D. Cal. Aug. 4, 2008). Maxwell argues that the materials are relevant because they may reveal monetary incentives to testify in a particular way. That argument demonstrates that the documents are being sought for impeachment. As stated above, the mere fact that certain documents might be impeachment evidence does not render them \"relevant\" for purposes of Rule 17(c); if at all, those documents would become relevant only after a witness testifies. See Skelos, 2018 WL 2254538, at *2. Maxwell's argument that the documents are relevant because their impeachment value is exculpatory does not get around this general bar. These materials only become relevant if or when those witnesses testify. She presents no other nonconclusory basis as to why they are exculpatory. Indeed, Maxwell concedes that the primary purpose of these documents will be for purposes of cross-examination, leaving little doubt as to the purported claim of relevance. And to the extent Maxwell posits that statements made as part of the EVCP process may be exculpatory in themselves, the argument is speculative because she provides no basis for why that expectation might be reasonable. The \"mere hope\" that the documents may contain some exculpatory evidence is insufficient to justify enforcement of a Rule 17(c) subpoena (or, as here, issuance of such a subpoena in the face of objections). See United States v. Rich, No. S 83-CR-579 (SWK), 1984 WL 845, at *3 (S.D.N.Y. Sept. 7, 1984). Maxwell's reliance on cases involving the Government's obligations under Brady and Giglio to produce impeachment evidence prior to trial are thus inapposite to the current context. Pena, 2016 WL 8735699, at *2-3. Maxwell thus fails to establish Request 12's compliance with the Nixon standards. Maxwell may renew her request for these documents once she identifies specific individuals whose submissions she seeks and spells out with specificity the relevance of all requested materials. At that time, the Court will determine whether it is proper to require production of these materials to",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "7",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004045",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Maxwell",
      "Aguilar",
      "Skelos",
      "Rich",
      "Pena",
      "Nixon",
      "Brady",
      "Giglio"
    ],
    "organizations": [
      "United States"
    ],
    "locations": [
      "N.D. Cal.",
      "S.D.N.Y."
    ],
    "dates": [
      "04/27/21",
      "Aug. 4, 2008",
      "Sept. 7, 1984"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 252",
      "CR 07-00030 (SBA)",
      "S 83-CR-579 (SWK)",
      "Request 12",
      "Rule 17(c)"
    ]
  },
  "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 7 of 9."
}