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2
README.md
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@ -32,12 +32,14 @@ This project automatically processes thousands of scanned document pages using A
```
.
├── process_images.py # Python script to OCR images using AI
├── cleanup_failed.py # Python script to clean up failed processing
├── deduplicate.py # Python script to deduplicate entities
├── analyze_documents.py # Python script to generate AI summaries
├── requirements.txt # Python dependencies
├── .env.example # Example environment configuration
├── downloads/ # Place document images here
├── results/ # Extracted JSON data per document
├── processing_index.json # Processing progress tracking (generated)
├── dedupe.json # Entity deduplication mappings (generated)
├── analyses.json # AI document analyses (generated)
├── src/ # 11ty source files for website

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analyses.json
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127
deduplicate.py
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@ -54,38 +54,54 @@ class EntityDeduplicator:
if entity_type == "people":
examples = """Examples:
{
{{
"Jeffrey Epstein": ["Jeffrey Epstein", "JEFFREY EPSTEIN", "Epstein", "EPSTEIN", "J. Epstein", "Jeffrey E. Epstein", "J Epstein", "Jeffery Epstein", "Mr. Epstein", "Jeffrey E.", "Epstein's"],
"Ghislaine Maxwell": ["Ghislaine Maxwell", "GHISLAINE MAXWELL", "Maxwell", "G. Maxwell", "Ghislane Maxwell", "Ghislain Maxwell", "Ms. Maxwell"],
"Bill Clinton": ["Bill Clinton", "BILL CLINTON", "Clinton", "William Clinton", "William J. Clinton", "President Clinton", "William Jefferson Clinton"],
"Prince Andrew": ["Prince Andrew", "PRINCE ANDREW", "Andrew", "Duke of York", "HRH Prince Andrew", "Prince Andrew, Duke of York"]
}
}}
CORRECT handling of numbered identifiers:
{{
"Accuser 1": ["Accuser 1", "Accuser-1", "Accuser 01", "ACCUSER 1"],
"Accuser 2": ["Accuser 2", "Accuser-2", "Accuser 02", "ACCUSER 2"],
"Accuser 3": ["Accuser 3", "Accuser-3", "Accuser 03"],
"Jane Doe 1": ["Jane Doe 1", "Jane Doe-1", "JANE DOE 1"],
"Jane Doe 2": ["Jane Doe 2", "Jane Doe-2"]
}}
WRONG EXAMPLES (DO NOT DO THIS):
{
{{
"Accusers 1-3": ["Accuser 1", "Accuser 2", "Accuser 3"] // WRONG - these are different people!
"Victims": ["Victim 1", "Victim 2", "Victim 3"] // WRONG - keep them separate
"Mr. Epstein's brother": ["Jeffrey Epstein", "Epstein"] // WRONG - use actual name
"The President": ["Bill Clinton"] // WRONG - use actual name
"Plaintiff's attorney": ["John Smith"] // WRONG - use actual name
}"""
}}"""
elif entity_type == "organizations":
examples = """Examples:
{
{{
"Federal Bureau of Investigation": ["Federal Bureau of Investigation", "FBI", "F.B.I.", "FEDERAL BUREAU OF INVESTIGATION", "Federal Bureau Of Investigation"],
"United States District Court": ["United States District Court", "U.S. District Court", "USDC", "District Court"],
"Victoria's Secret": ["Victoria's Secret", "VICTORIA'S SECRET", "Victorias Secret", "Victoria Secret"]
}"""
}}"""
else: # locations
examples = """Examples:
{
{{
"New York City": ["New York City", "NEW YORK CITY", "NYC", "New York", "New York, NY", "New York City, NY", "Manhattan"],
"Little Saint James": ["Little Saint James", "LITTLE SAINT JAMES", "Little St. James", "Little St James", "LSJ"],
"Palm Beach": ["Palm Beach", "PALM BEACH", "Palm Beach, Florida", "Palm Beach, FL"]
}"""
}}"""
return f"""You are an expert at identifying and merging duplicate entities in legal documents.
Given a list of {entity_type}, identify which names refer to the same entity and group them under their canonical name.
⚠️⚠️⚠️ CRITICAL WARNING ⚠️⚠️⚠️
The canonical name MUST be an actual person's PROPER NAME (First + Last).
NEVER use descriptive phrases like "Mr. X's brother" or "The defendant".
If you see "Jeffrey Epstein" in the list, that MUST be the canonical name, NOT "Mr. Epstein's brother".
CRITICAL RULES FOR CANONICAL NAMES:
**What makes a GOOD canonical name:**
@ -101,6 +117,13 @@ CRITICAL RULES FOR CANONICAL NAMES:
- Roles or relationships (e.g., "co-conspirator", "witness", "victim")
- Generic references (e.g., "he", "she", "defendant")
**CRITICAL: Do NOT merge numbered identifiers:**
- "Accuser 1", "Accuser 2", "Accuser 3" are DIFFERENT people - keep them separate
- "Victim 1", "Victim 2", "Victim 3" are DIFFERENT people - keep them separate
- "Witness 1", "Witness 2", "Witness 3" are DIFFERENT people - keep them separate
- "Jane Doe 1", "Jane Doe 2" are DIFFERENT people - keep them separate
- ONLY merge if the NUMBER is the same (e.g., "Accuser 1" = "Accuser-1" = "Accuser-01")
**Deduplication Rules:**
1. **Use Proper Names Only**: The canonical name MUST be an actual person's name
2. **Case Insensitive**: "EPSTEIN", "Epstein", "epstein" are all the same
@ -143,9 +166,23 @@ VALIDATION:
- Examples of GOOD canonical names: "Jeffrey Epstein", "Bill Clinton", "John Smith"
- Examples of BAD canonical names: "Mr. Epstein's brother", "The defendant", "Plaintiff"
STEP-BY-STEP PROCESS:
1. Look at the list of variants
2. Find the FULL PROPER NAME (e.g., "Jeffrey Epstein")
3. Use that as the canonical name
4. Add all other variants to the array
5. NEVER use descriptive phrases as canonical names
EXAMPLE THOUGHT PROCESS:
Variants: ["Jeffrey Epstein", "Epstein", "Mr. Epstein", "Mr. Epstein's brother", "J. Epstein"]
Question: Which is the actual person's full name?
Answer: "Jeffrey Epstein" ✓
NOT "Mr. Epstein's brother" ✗ (this is a description, not a name)
Result: {{"Jeffrey Epstein": ["Jeffrey Epstein", "Epstein", "Mr. Epstein", "Mr. Epstein's brother", "J. Epstein"]}}
Return ONLY valid JSON with NO extra text, markdown, or explanations."""
def deduplicate_entities(self, entities: List[str], entity_type: str, batch_size: int = 50) -> Dict[str, str]:
def deduplicate_entities(self, entities: List[str], entity_type: str, batch_size: int = 30) -> Dict[str, str]:
"""Use LLM to deduplicate entities, processing in batches"""
if not entities:
return {}
@ -167,10 +204,10 @@ Return ONLY valid JSON with NO extra text, markdown, or explanations."""
},
{
"role": "user",
"content": f"Identify duplicates in this list of {entity_type}:\n\n" + "\n".join(f"- {e}" for e in batch)
"content": f"Identify duplicates in this list of {entity_type}:\n\n" + "\n".join(f"- {e}" for e in batch) + "\n\nRemember: Use FULL PROPER NAMES as canonical (e.g., 'Jeffrey Epstein'), NOT descriptions (e.g., 'Mr. Epstein's brother')."
}
],
temperature=0.1,
temperature=0.0, # Make it deterministic
max_tokens=4096
)
@ -235,29 +272,55 @@ Return ONLY valid JSON with NO extra text, markdown, or explanations."""
for canonical, variants in groups.items():
# Validate canonical name for people
if entity_type == "people":
# Check for bad canonical names
bad_patterns = [
r"'s\s+(brother|sister|friend|attorney|lawyer|associate)",
r"^(the|a)\s+(defendant|plaintiff|witness|victim|judge|president)",
r"^mr\.|^ms\.|^mrs\.|^dr\.\s*$",
r"co-conspirator|witness\s+\d+|victim\s+\d+",
r"'s$" # ends with possessive
]
# Check if this incorrectly merged numbered identifiers
# e.g., "Accusers 1-3" should be split back into separate people
if re.search(r'(accuser|victim|witness|jane doe|john doe)s?\s*\d+\s*-\s*\d+', canonical, re.IGNORECASE):
# This is wrong - split it back
print(f" ⚠️ Incorrectly merged group: '{canonical}' - splitting back into individuals")
# Map each variant to itself
for variant in variants:
all_mappings[variant] = variant
continue
# Check for bad canonical names - be very aggressive
canonical_lower = canonical.lower()
for pattern in bad_patterns:
if re.search(pattern, canonical_lower):
# This is a bad canonical name - try to find a better one
# Look for the longest actual name in the variants
better_name = max(
(v for v in variants if len(v.split()) >= 2 and not re.search(pattern, v.lower())),
key=len,
default=canonical
)
if better_name != canonical:
# Pattern: anything with 's brother/sister/friend/attorney/mother/father etc
if re.search(r"'s\s+(brother|sister|friend|attorney|lawyer|associate|mother|father|son|daughter)", canonical_lower):
# Find actual name from variants
actual_names = [v for v in variants if not re.search(r"'s\s+(brother|sister|friend|attorney|lawyer|associate|mother|father|son|daughter)", v.lower())]
if actual_names:
# Prefer names with first and last name
full_names = [n for n in actual_names if len(n.split()) >= 2]
if full_names:
# Pick the longest/most complete
better_name = max(full_names, key=len)
print(f" ⚠️ Fixed bad canonical: '{canonical}' → '{better_name}'")
canonical = better_name
break
# Pattern: "The X" or "A X" (defendant, plaintiff, etc)
elif re.search(r"^(the|a)\s+(defendant|plaintiff|witness|victim|judge|president)", canonical_lower):
actual_names = [v for v in variants if not re.search(r"^(the|a)\s+", v.lower()) and len(v.split()) >= 2]
if actual_names:
better_name = max(actual_names, key=len)
print(f" ⚠️ Fixed bad canonical: '{canonical}' → '{better_name}'")
canonical = better_name
# Pattern: ends with possessive
elif canonical_lower.endswith("'s") or canonical_lower.endswith("'s"):
non_possessive = [v for v in variants if not (v.lower().endswith("'s") or v.lower().endswith("'s"))]
if non_possessive:
better_name = max(non_possessive, key=len)
print(f" ⚠️ Fixed bad canonical: '{canonical}' → '{better_name}'")
canonical = better_name
# Pattern: just title (Mr., Ms., Dr.) alone
elif re.match(r"^(mr|ms|mrs|dr|judge|president)\.?\s*$", canonical_lower):
actual_names = [v for v in variants if len(v.split()) >= 2]
if actual_names:
better_name = max(actual_names, key=len)
print(f" ⚠️ Fixed bad canonical: '{canonical}' → '{better_name}'")
canonical = better_name
for variant in variants:
all_mappings[variant] = canonical
@ -288,7 +351,7 @@ Return ONLY valid JSON with NO extra text, markdown, or explanations."""
return final_mappings
def process_all(self, batch_size: int = 50) -> Dict[str, Dict[str, str]]:
def process_all(self, batch_size: int = 30) -> Dict[str, Dict[str, str]]:
"""Process all entity types"""
print("=" * 60)
print("ENTITY DEDUPLICATION")
@ -340,7 +403,7 @@ def main():
parser.add_argument("--api-url", help="OpenAI-compatible API base URL")
parser.add_argument("--api-key", help="API key")
parser.add_argument("--model", help="Model name")
parser.add_argument("--batch-size", type=int, default=50, help="Entities per batch (default: 50)")
parser.add_argument("--batch-size", type=int, default=30, help="Entities per batch (default: 30)")
parser.add_argument("--show-stats", action="store_true", help="Show current deduplication stats and exit")
args = parser.parse_args()

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processing_index.json
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@ -9889,7 +9889,617 @@
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{
"document_metadata": {
"page_number": "12",
"document_number": "9:08-cv-80736",
"date": "07/13/2010",
"document_type": "Court Document",
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"full_text": "Agreement. The Non-Prosecution Agreement does not bar the United States from bringing federal criminal charges against Epstein for the offenses set forth in the Non-Prosecution Agreement in any other district in the nation.11 See, e.g., United States v. Cain, 587 F.2d 678, 680 (5th Cir. 1979) (\"Where . . . the prosecutor is not found to have made promises relating to nonprosecution of charges in another district and the [defendant] is not found to have relied on such alleged promises, this Court will affirm the trial court's denial of a motion to dismiss the subsequent prosecutions.\") Neither does the Non-Prosecution Agreement bar prosecution in any district for offenses not identified in the agreement.\n\nPetitioners contend that the CVRA gives a victim the right to confer with the attorney for the government before there is a disposition of contemplated, but-not-yet-filed federal criminal charges arising from offenses against the victim. But, although the government disputes that the CVRA creates such a right,12 the Petitioners have never been denied any such right. The Petitioners have had and still have the ability confer to with the attorney for the government about potential federal criminal charges against Epstein and about the potential disposition of any such charges, should they be filed. In fact, Petitioners are free to approach the United States Attorney's Offices in districts such as the Southern District of New York and the District of New Jersey - whose authority to institute criminal charges against Epstein in their districts has not\n\n11 Significantly, under the governing provision of the United States Attorney's Manual, the USAO-SDFL did not have the authority to unilaterally bar Epstein's prosecution in any other district in the country:\n\nNo district or division shall make any agreement, including any agreement not to prosecute, which purports to bind any other district(s) or division without the express written approval of the United States Attorney(s) in each affected district and/or the Assistant Attorney General of the Criminal Division.\n\nUSAM 9-27.641 (Multi-District (Global) Agreement Requests).\n\n12 The government acknowledges that this Court has nonetheless ruled that \"as a matter of law the CVRA can apply before formal charges are filed,\" DE 99 at 10; see also id. at 6-9, but has not yet determined \"whether the particular rights asserted here attached,\" id. at 10.\n\n11",
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"content": "Agreement. The Non-Prosecution Agreement does not bar the United States from bringing federal criminal charges against Epstein for the offenses set forth in the Non-Prosecution Agreement in any other district in the nation.11 See, e.g., United States v. Cain, 587 F.2d 678, 680 (5th Cir. 1979) (\"Where . . . the prosecutor is not found to have made promises relating to nonprosecution of charges in another district and the [defendant] is not found to have relied on such alleged promises, this Court will affirm the trial court's denial of a motion to dismiss the subsequent prosecutions.\") Neither does the Non-Prosecution Agreement bar prosecution in any district for offenses not identified in the agreement.",
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"content": "Petitioners contend that the CVRA gives a victim the right to confer with the attorney for the government before there is a disposition of contemplated, but-not-yet-filed federal criminal charges arising from offenses against the victim. But, although the government disputes that the CVRA creates such a right,12 the Petitioners have never been denied any such right. The Petitioners have had and still have the ability confer to with the attorney for the government about potential federal criminal charges against Epstein and about the potential disposition of any such charges, should they be filed. In fact, Petitioners are free to approach the United States Attorney's Offices in districts such as the Southern District of New York and the District of New Jersey - whose authority to institute criminal charges against Epstein in their districts has not",
"position": "middle"
},
{
"type": "printed",
"content": "11 Significantly, under the governing provision of the United States Attorney's Manual, the USAO-SDFL did not have the authority to unilaterally bar Epstein's prosecution in any other district in the country:\n\nNo district or division shall make any agreement, including any agreement not to prosecute, which purports to bind any other district(s) or division without the express written approval of the United States Attorney(s) in each affected district and/or the Assistant Attorney General of the Criminal Division.\n\nUSAM 9-27.641 (Multi-District (Global) Agreement Requests).",
"position": "middle"
},
{
"type": "printed",
"content": "12 The government acknowledges that this Court has nonetheless ruled that \"as a matter of law the CVRA can apply before formal charges are filed,\" DE 99 at 10; see also id. at 6-9, but has not yet determined \"whether the particular rights asserted here attached,\" id. at 10.",
"position": "bottom"
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"entities": {
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],
"dates": [
"07/13/2010"
],
"reference_numbers": [
"9:08-cv-80736",
"DE 99",
"USAM 9-27.641"
]
},
"additional_notes": "The document appears to be a court filing related to the case of Epstein, with discussions around the Non-Prosecution Agreement and the Crime Victims' Rights Act (CVRA). The text is mostly printed, with no visible handwriting or stamps. The document is from page 12 of a larger filing."
}

71
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@ -0,0 +1,71 @@
{
"document_metadata": {
"page_number": "9",
"document_number": "14",
"date": "07/15/19",
"document_type": "Court Transcript",
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},
"full_text": "Case 1:19-cr-00490-RMB Document 14 Filed 07/15/19 Page 9 of 18\nSORA HEARING page 8\n1 more than seven days or at least he has not since he has\n2 been registered. He has no intention to ever be here for\n3 longer than a period of ten days.\n4 Like I said, he does notify the authorities when\n5 he is here. He fully understands the reason for voluntary\n6 registration, he wants to be compliant with the Federal SORA\n7 law which requires wherever you own a property to register.\n8\n9 To require Mr. Epstein to register as a Level\n10 come to New York more than he does normally, it would\n11 require him to come every 90 days and renew his\n12 registration.\n13 He is very diligent in registering with New York\n14 authorities.\n15\n16 All of the other jurisdictions that have\n17 considered his case have determined that he either not\n18 register at all or register at the lowest level, and he has\n19 been more than compliant with all of those requirements.\n20 Your Honor, we would join in the prosecutor's\n21 application.\n22\n23 THE COURT: I am sure you would.\n24 MS. MUSUMECI: By way of background, we have been\n25 in contact with the prosecutor's office on this matter since\nI believe certainly since Mr. Epstein got his notification,\nwhich I believe was in August. We have met with the\nVikki J. Benkel\nSenior Court Reporter\nDOJ-OGR-00000374",
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{
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"content": "more than seven days or at least he has not since he has\nbeen registered. He has no intention to ever be here for\nlonger than a period of ten days.\nLike I said, he does notify the authorities when\nhe is here. He fully understands the reason for voluntary\nregistration, he wants to be compliant with the Federal SORA\nlaw which requires wherever you own a property to register.\nTo require Mr. Epstein to register as a Level\ncome to New York more than he does normally, it would\nrequire him to come every 90 days and renew his\nregistration.\nHe is very diligent in registering with New York\nauthorities.\nAll of the other jurisdictions that have\nconsidered his case have determined that he either not\nregister at all or register at the lowest level, and he has\nbeen more than compliant with all of those requirements.\nYour Honor, we would join in the prosecutor's\napplication.",
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"content": "THE COURT: I am sure you would.",
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"content": "MS. MUSUMECI: By way of background, we have been\nin contact with the prosecutor's office on this matter since\nI believe certainly since Mr. Epstein got his notification,\nwhich I believe was in August. We have met with the",
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}

62
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{
"document_metadata": {
"page_number": "27",
"document_number": "36",
"date": "07/24/19",
"document_type": "court transcript",
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"full_text": "Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 27 of 74\n\n1 to registration which was part of the obligations that he accepted, and no one quarrels with his performance.\n2\n3 He went to the state. They returned the higher charge. He went to jail. He did his strict probation with\n4 home detention. And he's been registered since 2010.\n5\n6 I think these facts are important, not just because they are the cornerstone of a potential legal defense, and I\n7 won't go through all of the different factors that we believe on a principal basis will distinguish this case from the\n8 precedence that Mr. Rossmiller is relying on.\n9\n10 These were not two silos. The Southern District didn't stand completely detached from the activities and the\n11 events in Florida. But that's a motion to dismiss that will be brought later.\n12 The premise is if we're right and they're wrong and he's detained, he's lost freedom without punishment.\n13\n14 Your Honor asked about the rebuttable presumption, and I think this also goes back to the events of the 2007 and 2008\n15 era.\n16\n17 THE COURT: So the presumption, first of all, the people who wrote that presumption into law clearly know about\n18 bail and history and the need for defendants to consult with their counsel, etc.\n19\n20 But in this rather narrow class of cases, almost all of them I think relating to children or young people, there are\n21 a whole series of cases, exceptions to be sure, where the\n22\n23 SOUTHERN DISTRICT REPORTERS, P.C.\n24 (212) 805-0300\n25\nDOJ-OGR-00000537",
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"content": "1 to registration which was part of the obligations that he accepted, and no one quarrels with his performance.\nHe went to the state. They returned the higher charge. He went to jail. He did his strict probation with home detention. And he's been registered since 2010.\nI think these facts are important, not just because they are the cornerstone of a potential legal defense, and I won't go through all of the different factors that we believe on a principal basis will distinguish this case from the precedence that Mr. Rossmiller is relying on.\nThese were not two silos. The Southern District didn't stand completely detached from the activities and the events in Florida. But that's a motion to dismiss that will be brought later.\nThe premise is if we're right and they're wrong and he's detained, he's lost freedom without punishment.\nYour Honor asked about the rebuttable presumption, and I think this also goes back to the events of the 2007 and 2008 era.",
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"content": "THE COURT: So the presumption, first of all, the people who wrote that presumption into law clearly know about bail and history and the need for defendants to consult with their counsel, etc.\nBut in this rather narrow class of cases, almost all of them I think relating to children or young people, there are a whole series of cases, exceptions to be sure, where the",
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79
results/IMAGES001/DOJ-OGR-00000801.json Normal file
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{
"document_metadata": {
"page_number": "18",
"document_number": "Case 1:19-cr-00290-RMB Document 32 Filed 07/18/19 Page 18 of 33",
"date": "07/18/2019",
"document_type": "Court Document",
"has_handwriting": false,
"has_stamps": false
},
"full_text": "payments appears to be recurring or repeating during the approximately five years of bank records presently available to the Government. This course of action, and in particular its timing, suggests the defendant was attempting to further influence co-conspirators who might provide information against him in light of the recently re-emerging allegations. Id. A court may order detention if there is a serious risk that the defendant will attempt to threaten, injure, or intimidate a prospective witness or juror. 18 U.S.C. § 3142(f)(2)(B). Even a single incident of witness tampering has been a \"traditional ground for pretrial detention by the courts.\" LaFontaine, 210 F.3d at 132-34 (affirming then-U.S. District Judge Michael B. Mukasey's denial of bail to a defendant who had met with a prospective witness in an effort to persuade the witness to give untruthful testimony and where there was \"no evidence of influence, harassment or intimidation'); see also United States v. Singh, 2012 WL 3260232, at *3 (E.D.N.Y. Aug. 8, 2012). Mr. Epstein Has Not Always Been Compliant With His Legal Obligations As A Registered Sex Offender Defense counsel has contended that Mr. Epstein has been \"scrupulously fulfill[ing] his obligations in every jurisdiction in which he was required to register [as a sex offender],\" since his 2008 Florida convictions. Counsel argues that this shows that he \"is no longer a danger to anyone and will faithfully obey all conditions of release if ordered.\" Dkt. 6 at 3. The record shows that Mr. Epstein has challenged his sex offender \"level\" in at least one jurisdiction since 2008 in an effort to minimize his reporting obligations. And, one recent press account states that Epstein is not in compliance in New York State. See Elizabeth Rosner, Tina Moore, Larry Celona, and Bruce Golding, NYPD let convicted pedophile Jeffrey Epstein skip judge-ordered check-in, New York Post, July 10, 2019 (\"July 10, 2019 NY Post Article\") 18 DOJ-OGR-00000801",
"text_blocks": [
{
"type": "printed",
"content": "payments appears to be recurring or repeating during the approximately five years of bank records presently available to the Government. This course of action, and in particular its timing, suggests the defendant was attempting to further influence co-conspirators who might provide information against him in light of the recently re-emerging allegations. Id.",
"position": "top"
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{
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"content": "A court may order detention if there is a serious risk that the defendant will attempt to threaten, injure, or intimidate a prospective witness or juror. 18 U.S.C. § 3142(f)(2)(B). Even a single incident of witness tampering has been a \"traditional ground for pretrial detention by the courts.\" LaFontaine, 210 F.3d at 132-34 (affirming then-U.S. District Judge Michael B. Mukasey's denial of bail to a defendant who had met with a prospective witness in an effort to persuade the witness to give untruthful testimony and where there was \"no evidence of influence, harassment or intimidation'); see also United States v. Singh, 2012 WL 3260232, at *3 (E.D.N.Y. Aug. 8, 2012).",
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"content": "Mr. Epstein Has Not Always Been Compliant With His Legal Obligations As A Registered Sex Offender",
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"content": "Defense counsel has contended that Mr. Epstein has been \"scrupulously fulfill[ing] his obligations in every jurisdiction in which he was required to register [as a sex offender],\" since his 2008 Florida convictions. Counsel argues that this shows that he \"is no longer a danger to anyone and will faithfully obey all conditions of release if ordered.\" Dkt. 6 at 3.",
"position": "middle"
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{
"type": "printed",
"content": "The record shows that Mr. Epstein has challenged his sex offender \"level\" in at least one jurisdiction since 2008 in an effort to minimize his reporting obligations. And, one recent press account states that Epstein is not in compliance in New York State. See Elizabeth Rosner, Tina Moore, Larry Celona, and Bruce Golding, NYPD let convicted pedophile Jeffrey Epstein skip judge-ordered check-in, New York Post, July 10, 2019 (\"July 10, 2019 NY Post Article\")",
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},
"additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. The text is printed and there are no visible stamps or handwritten notes. The document is page 18 of 33."
}

60
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{
"document_metadata": {
"page_number": "119",
"document_number": "20-2",
"date": "04/01/2021",
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"full_text": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page119 of 200\n56\n1 hiding. She is a risk of flight because she changed her e-mail\n2 and phone number. That's what we heard in the opening brief.\n3 Well, what happened? Something the government, frankly, should\n4 know about, because it was certainly public, last year, in a\n5 civil litigation, in August of 2019, right around the time of\n6 the arrest of Mr. Epstein, the Second Circuit ruled that\n7 certain records in one of the civil cases should be unsealed\n8 and released to the public. That was done. There was no stay\n9 at the moment. The demand was issued, and the documents were\n10 released. Certain of those documents were supposed to be\n11 redacted and sometimes they were and sometimes they were not,\n12 documents including e-mail addresses, Social Security numbers,\n13 names, phone numbers, the sorts of things your Honor, I am\n14 sure, has to deal with all the time in these kinds of\n15 situations.\n16 But as it turned out, for whatever reason, some of the\n17 documents were not redacted and her e-mail address was\n18 revealed. Shortly after that, she starts getting strange\n19 e-mails. Her phone is hacked, and she had to change e-mails\n20 and change the account.\n21 Now she has got a phone that has legal materials on\n22 it, correspondence with her counsel in civil litigation that's\n23 been hacked, so she keeps it. Why does she keep it? Because\n24 she is in civil litigation. Her obligation is to keep\n25 evidence, not destroy it, and is advised that a way to keep it\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001060",
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"content": "1 hiding. She is a risk of flight because she changed her e-mail\n2 and phone number. That's what we heard in the opening brief.\n3 Well, what happened? Something the government, frankly, should\n4 know about, because it was certainly public, last year, in a\n5 civil litigation, in August of 2019, right around the time of\n6 the arrest of Mr. Epstein, the Second Circuit ruled that\n7 certain records in one of the civil cases should be unsealed\n8 and released to the public. That was done. There was no stay\n9 at the moment. The demand was issued, and the documents were\n10 released. Certain of those documents were supposed to be\n11 redacted and sometimes they were and sometimes they were not,\n12 documents including e-mail addresses, Social Security numbers,\n13 names, phone numbers, the sorts of things your Honor, I am\n14 sure, has to deal with all the time in these kinds of\n15 situations.\n16 But as it turned out, for whatever reason, some of the\n17 documents were not redacted and her e-mail address was\n18 revealed. Shortly after that, she starts getting strange\n19 e-mails. Her phone is hacked, and she had to change e-mails\n20 and change the account.\n21 Now she has got a phone that has legal materials on\n22 it, correspondence with her counsel in civil litigation that's\n23 been hacked, so she keeps it. Why does she keep it? Because\n24 she is in civil litigation. Her obligation is to keep\n25 evidence, not destroy it, and is advised that a way to keep it",
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}

74
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{
"document_metadata": {
"page_number": "3",
"document_number": "20-cr-00330-AJN Document 110 Filed 06/22/20 Page 7 of 15",
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"full_text": "here. Whether or not the accusers' recollections as to Epstein are corroborated is irrelevant to the strength of the evidence against Ms. Maxwell. The only purported corroboration that pertains in any way to Ms. Maxwell is of marginal value. The government references (Id. at 11). But even the government concedes that, at best, It is clear that the only evidence that Ms. Maxwell allegedly \"groomed\" the accusers or knowingly facilitated or participated in Epstein's sexual abuse of minors will come solely from the testimony of the three accusers. The government's case against Ms. Maxwell therefore rests entirely on the credibility and reliability of these three witnesses. Moreover, the substantive counts (Counts Two and Four) are based on the testimony of only one witness, Minor Victim-1. It is also telling that the government does not even attempt to rebut the defense's assertion that it did not begin issuing subpoenas for documents related to Ms. Maxwell until just after the death of Jeffrey Epstein. This confirms that the case against Ms. Maxwell was assembled after the fact 1 The government also proffers that they will have \"additional witnesses.\" (Gov. Mem. at 11). But these are not \"outcry\" witnesses who will corroborate a contemporaneous account of abuse from one or more of the accusers. Instead, they will testify only that \"both [Ms. Maxwell] and Epstein knew and interacted with certain minor victims when those victims were minors.\" (Id.). Again, the fact that Ms. Maxwell may have \"met and interacted with\" someone when they were a minor proves absolutely nothing. 2 One of the witnesses has submitted a letter to the Court. While the CVRA permits the right to be heard, the letter should be given no legal weight in the Court's bail analysis. See United States v. Turner, 367 F. Supp. 2d 319, 331-32 (E.D.N.Y. 2005) 3 DOJ-OGR-00001192",
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"content": "here. Whether or not the accusers' recollections as to Epstein are corroborated is irrelevant to the strength of the evidence against Ms. Maxwell.",
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"content": "The only purported corroboration that pertains in any way to Ms. Maxwell is of marginal value. The government references (Id. at 11). But even the government concedes that, at best,",
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"content": "It is clear that the only evidence that Ms. Maxwell allegedly \"groomed\" the accusers or knowingly facilitated or participated in Epstein's sexual abuse of minors will come solely from the testimony of the three accusers. The government's case against Ms. Maxwell therefore rests entirely on the credibility and reliability of these three witnesses. Moreover, the substantive counts (Counts Two and Four) are based on the testimony of only one witness, Minor Victim-1.",
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{
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"content": "It is also telling that the government does not even attempt to rebut the defense's assertion that it did not begin issuing subpoenas for documents related to Ms. Maxwell until just after the death of Jeffrey Epstein. This confirms that the case against Ms. Maxwell was assembled after the fact",
"position": "middle"
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{
"type": "printed",
"content": "1 The government also proffers that they will have \"additional witnesses.\" (Gov. Mem. at 11). But these are not \"outcry\" witnesses who will corroborate a contemporaneous account of abuse from one or more of the accusers. Instead, they will testify only that \"both [Ms. Maxwell] and Epstein knew and interacted with certain minor victims when those victims were minors.\" (Id.). Again, the fact that Ms. Maxwell may have \"met and interacted with\" someone when they were a minor proves absolutely nothing.",
"position": "bottom"
},
{
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"content": "2 One of the witnesses has submitted a letter to the Court. While the CVRA permits the right to be heard, the letter should be given no legal weight in the Court's bail analysis. See United States v. Turner, 367 F. Supp. 2d 319, 331-32 (E.D.N.Y. 2005)",
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}

70
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{
"document_metadata": {
"page_number": "2",
"document_number": "Case 1:20-cr-00330-AJN Document 103-21 Filed 12/23/20 Page 2 of 4",
"date": "December 23, 2020",
"document_type": "Addendum Opinion",
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"full_text": "IN THE MATTER OF AN OPINION ON THE EXTRADITION LAW OF ENGLAND AND WALES RE GHISLAINE MAXWELL ADDENDUM OPINION 1. This Addendum Opinion is provided in response to the Government's Memorandum in Opposition to the Defendant's Renewed Motion to Release dated 16 December 2020, insofar as it pertains to matters of English extradition law and practice. 2. The primary conclusions of the Opinion dated 8 October 2020 ('the Opinion') remain unchanged, namely: (a) in the majority of cases, proceedings in England and Wales in relation to US extradition requests are concluded in under two years; (b) it is virtually certain that bail would be refused in an extradition case in circumstances where the requested person had absconded from criminal proceedings in the United States prior to trial and in breach of bail; and (c) on the basis of the information currently known, it is highly unlikely1 that Ghislaine Maxwell would be able successfully to resist extradition to the United States in relation to the charges in the superseding indictment dated 7 July 2020. In addition to those conclusions, the following three points may be made. 3. First, as noted in the Opinion2, Ms Maxwell's waiver of extradition would be admissible in any extradition proceedings in England and Wales. While such a document cannot compel a requested person to consent to their extradition once in the United Kingdom, the document would be a highly relevant factor in any contested extradition proceedings. In particular: (a) If Ms Maxwell were to rely on such a waiver to secure bail in the United States and then, having absconded, renege on the undertakings in that 1 The Government observes, at p.16 of the Motion, that this leaves open a \"possibility\" that extradition could be resisted. Absolute certainty in any legal context is rare but the practical effect of the conclusion in the Opinion is that, at this stage and on the basis of the information currently known, it is difficult to conceive of circumstances in which Ms Maxwell could successfully resist extradition, and her extradition would be a virtual foregone conclusion. 2 Opinion, para. 39. DOJ-OGR-00001206",
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"content": "1. This Addendum Opinion is provided in response to the Government's Memorandum in Opposition to the Defendant's Renewed Motion to Release dated 16 December 2020, insofar as it pertains to matters of English extradition law and practice.",
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{
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"content": "2. The primary conclusions of the Opinion dated 8 October 2020 ('the Opinion') remain unchanged, namely: (a) in the majority of cases, proceedings in England and Wales in relation to US extradition requests are concluded in under two years; (b) it is virtually certain that bail would be refused in an extradition case in circumstances where the requested person had absconded from criminal proceedings in the United States prior to trial and in breach of bail; and (c) on the basis of the information currently known, it is highly unlikely1 that Ghislaine Maxwell would be able successfully to resist extradition to the United States in relation to the charges in the superseding indictment dated 7 July 2020. In addition to those conclusions, the following three points may be made.",
"position": "body"
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{
"type": "printed",
"content": "3. First, as noted in the Opinion2, Ms Maxwell's waiver of extradition would be admissible in any extradition proceedings in England and Wales. While such a document cannot compel a requested person to consent to their extradition once in the United Kingdom, the document would be a highly relevant factor in any contested extradition proceedings. In particular: (a) If Ms Maxwell were to rely on such a waiver to secure bail in the United States and then, having absconded, renege on the undertakings in that",
"position": "body"
},
{
"type": "printed",
"content": "1 The Government observes, at p.16 of the Motion, that this leaves open a \"possibility\" that extradition could be resisted. Absolute certainty in any legal context is rare but the practical effect of the conclusion in the Opinion is that, at this stage and on the basis of the information currently known, it is difficult to conceive of circumstances in which Ms Maxwell could successfully resist extradition, and her extradition would be a virtual foregone conclusion. 2 Opinion, para. 39.",
"position": "footer"
},
{
"type": "printed",
"content": "DOJ-OGR-00001206",
"position": "footer"
}
],
"entities": {
"people": [
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"Ms Maxwell"
],
"organizations": [
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],
"locations": [
"England",
"Wales",
"United Kingdom",
"United States"
],
"dates": [
"8 October 2020",
"16 December 2020",
"7 July 2020",
"December 23, 2020"
],
"reference_numbers": [
"Case 1:20-cr-00330-AJN Document 103-21",
"DOJ-OGR-00001206"
]
},
"additional_notes": "The document appears to be a formal legal opinion regarding the extradition of Ghislaine Maxwell to the United States. The text is well-formatted and printed, with no visible handwriting or stamps. The document includes footnotes and references to specific paragraphs and pages of other documents."
}

62
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@ -0,0 +1,62 @@
{
"document_metadata": {
"page_number": "10",
"document_number": "40-1",
"date": "04/12/2021",
"document_type": "court document",
"has_handwriting": false,
"has_stamps": false
},
"full_text": "Case 21-770, Document 40-1, 04/12/2021, 3075763, Page10 of 25\n\nGovernment's proffer that \"additional evidence, including flight records and other witnesses' corroborating testimony, will further support the main witnesses' testimony and link [Maxwell] to Epstein's conduct.\" (Id. at 10). She thus concluded that the case against Maxwell \"remains strong.\" (Id.).\n\n19. Judge Nathan found that Maxwell \"continues to have substantial international ties and multiple foreign citizenships, and she continues to have familial and personal connections abroad.\" (Id. at 11). Judge Nathan was unpersuaded by Maxwell's offer to consent to extradition, noting that the \"legal weight of the waivers is, at best, contested\" and therefore the risk of flight remained \"fundamentally unchanged.\" (Id. at 11-13). Judge Nathan further explained that Maxwell's \"extraordinary financial resources also continue to provide her the means to flee the country and to do so undetected.\" (Id. at 13). Judge Nathan acknowledged that \"letters of support\" written by friends and family \"substantiate the Defendant's claim that she has important ties to people in the United States,\" but found that the letters \"leave unaltered the Court's conclusion that flight would not pose an insurmountable burden\" for Maxwell in light of, among other things, her claim at the time of arrest that she was getting divorced, her lack of employment, and her significant ties to family and friends abroad. (Id. at 14-15).\n\n20. Judge Nathan emphasized that Maxwell's \"pattern of providing",
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"content": "Government's proffer that \"additional evidence, including flight records and other witnesses' corroborating testimony, will further support the main witnesses' testimony and link [Maxwell] to Epstein's conduct.\" (Id. at 10). She thus concluded that the case against Maxwell \"remains strong.\" (Id.).",
"position": "top"
},
{
"type": "printed",
"content": "19. Judge Nathan found that Maxwell \"continues to have substantial international ties and multiple foreign citizenships, and she continues to have familial and personal connections abroad.\" (Id. at 11). Judge Nathan was unpersuaded by Maxwell's offer to consent to extradition, noting that the \"legal weight of the waivers is, at best, contested\" and therefore the risk of flight remained \"fundamentally unchanged.\" (Id. at 11-13). Judge Nathan further explained that Maxwell's \"extraordinary financial resources also continue to provide her the means to flee the country and to do so undetected.\" (Id. at 13). Judge Nathan acknowledged that \"letters of support\" written by friends and family \"substantiate the Defendant's claim that she has important ties to people in the United States,\" but found that the letters \"leave unaltered the Court's conclusion that flight would not pose an insurmountable burden\" for Maxwell in light of, among other things, her claim at the time of arrest that she was getting divorced, her lack of employment, and her significant ties to family and friends abroad. (Id. at 14-15).",
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}
],
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},
"additional_notes": "The document appears to be a court document related to the case against Ghislaine Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 10 of 25."
}

73
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@ -0,0 +1,73 @@
{
"document_metadata": {
"page_number": "13",
"document_number": "73",
"date": "05/27/2021",
"document_type": "court document",
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},
"full_text": "Case 21-770, Document 73, 05/27/2021, 3109708, Page13 of 24\n\n\"renewed motion for pretrial relief,\" is both procedurally improper and substantively meritless. It should be denied.\n\nA. Applicable Law\n\n23. When seeking pretrial detention, the Government bears the burden of showing, by a preponderance of the evidence, that the defendant poses a risk of flight, and that no condition or combination of conditions would reasonably assure her presence in court. See 18 U.S.C. § 3142(f); United States v. Sabhnani, 493 F.3d 63, 75 (2d Cir. 2007).\n\n24. Where the defendant is charged with certain offenses, including offenses involving a minor victim under 18 U.S.C. §§ 2422 or 2423, a statutory presumption arises \"that no condition or combination of conditions will reasonably assure the appearance of the person as required . . .\" 18 U.S.C. § 3142(e)(3)(E). In such a case, the defendant \"bears a limited burden of production—not a burden of persuasion—to rebut that presumption by coming forward with evidence that he does not pose . . . a risk of flight.\" United States v. Mercedes, 254 F.3d 433, 436 (2d Cir. 2001).\n\n25. Where the Government seeks detention based on flight risk, the court must consider: (1) \"the nature and circumstances of the offense charged\"; (2)",
"text_blocks": [
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"content": "\"renewed motion for pretrial relief,\" is both procedurally improper and substantively meritless. It should be denied.",
"position": "top"
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{
"type": "printed",
"content": "A. Applicable Law",
"position": "top"
},
{
"type": "printed",
"content": "23. When seeking pretrial detention, the Government bears the burden of showing, by a preponderance of the evidence, that the defendant poses a risk of flight, and that no condition or combination of conditions would reasonably assure her presence in court. See 18 U.S.C. § 3142(f); United States v. Sabhnani, 493 F.3d 63, 75 (2d Cir. 2007).",
"position": "middle"
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{
"type": "printed",
"content": "24. Where the defendant is charged with certain offenses, including offenses involving a minor victim under 18 U.S.C. §§ 2422 or 2423, a statutory presumption arises \"that no condition or combination of conditions will reasonably assure the appearance of the person as required . . .\" 18 U.S.C. § 3142(e)(3)(E). In such a case, the defendant \"bears a limited burden of production—not a burden of persuasion—to rebut that presumption by coming forward with evidence that he does not pose . . . a risk of flight.\" United States v. Mercedes, 254 F.3d 433, 436 (2d Cir. 2001).",
"position": "middle"
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"type": "printed",
"content": "25. Where the Government seeks detention based on flight risk, the court must consider: (1) \"the nature and circumstances of the offense charged\"; (2)",
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]
},
"additional_notes": "The document appears to be a court filing related to a case involving pretrial detention. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
}

82
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{
"document_metadata": {
"page_number": "1",
"document_number": "1",
"date": "06/29/20",
"document_type": "Indictment",
"has_handwriting": false,
"has_stamps": false
},
"full_text": "Case 1:20-cr-00330-AJN Document 1 Filed 06/29/20 Page 1 of 18\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\nUNITED STATES OF AMERICA\n- v. -\nGHISLAINE MAXWELL,\nDefendant.\n\nSEALED INDICTMENT\n20 Cr. 330\n\nCOUNT ONE\n(Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts)\n\nThe Grand Jury charges:\n\nOVERVIEW\n1. The charges set forth herein stem from the role of GHISLAINE MAXWELL, the defendant, in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. In particular, from at least in or about 1994, up to and including at least in or about 1997, MAXWELL assisted, facilitated, and contributed to Jeffrey Epstein's abuse of minor girls by, among other things, helping Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that certain victims were in fact under the age of 18.\n2. As a part and in furtherance of their scheme to abuse minor victims, GHISLAINE MAXWELL, the defendant, and Jeffrey Epstein enticed and caused minor victims to travel to",
"text_blocks": [
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"content": "Case 1:20-cr-00330-AJN Document 1 Filed 06/29/20 Page 1 of 18",
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"content": "UNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK",
"position": "top"
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{
"type": "printed",
"content": "UNITED STATES OF AMERICA\n- v. -\nGHISLAINE MAXWELL,\nDefendant.",
"position": "top"
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{
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"content": "SEALED INDICTMENT\n20 Cr. 330",
"position": "top"
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{
"type": "printed",
"content": "COUNT ONE\n(Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts)",
"position": "middle"
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{
"type": "printed",
"content": "The Grand Jury charges:",
"position": "middle"
},
{
"type": "printed",
"content": "OVERVIEW\n1. The charges set forth herein stem from the role of GHISLAINE MAXWELL, the defendant, in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. In particular, from at least in or about 1994, up to and including at least in or about 1997, MAXWELL assisted, facilitated, and contributed to Jeffrey Epstein's abuse of minor girls by, among other things, helping Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that certain victims were in fact under the age of 18.",
"position": "middle"
},
{
"type": "printed",
"content": "2. As a part and in furtherance of their scheme to abuse minor victims, GHISLAINE MAXWELL, the defendant, and Jeffrey Epstein enticed and caused minor victims to travel to",
"position": "middle"
},
{
"type": "printed",
"content": "DOJ-OGR-00001467",
"position": "footer"
}
],
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],
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],
"dates": [
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"1997"
],
"reference_numbers": [
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]
},
"additional_notes": "The document appears to be a sealed indictment against Ghislaine Maxwell, with charges related to conspiracy to entice minors to travel for illegal sex acts. The document is from the United States District Court, Southern District of New York, and is dated June 29, 2020."
}

72
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{
"document_metadata": {
"page_number": "11",
"document_number": "1",
"date": "06/29/20",
"document_type": "Indictment",
"has_handwriting": false,
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},
"full_text": "Case 1:20-cr-00330-AJN Document 1 Filed 06/29/20 Page 11 of 18\na. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple group sexual encounters with Epstein and Minor Victim-1 in New York and Florida.\nb. In or about 1996, when Minor Victim-1 was under the age of 18, Minor Victim-1 was enticed to travel from Florida to New York for purposes of sexually abusing her at the New York Residence, in violation of New York Penal Law, Section 130.55.\nc. In or about 1996, when Minor Victim-2 was under the age of 18, MAXWELL provided Minor Victim-2 with an unsolicited massage in New Mexico, during which Minor Victim-2 was topless.\nd. Between in or about 1994 and in or about 1995, when Minor Victim-3 was under the age of 18, MAXWELL encouraged Minor Victim-3 to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Minor Victim-3 during those massages.\n(Title 18, United States Code, Section 371.)\nCOUNT TWO\n(Enticement of a Minor to Travel to Engage in Illegal Sex Acts)\nThe Grand Jury further charges:\n12. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within.\n11\nDOJ-OGR-00001477",
"text_blocks": [
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"content": "a. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple group sexual encounters with Epstein and Minor Victim-1 in New York and Florida.\nb. In or about 1996, when Minor Victim-1 was under the age of 18, Minor Victim-1 was enticed to travel from Florida to New York for purposes of sexually abusing her at the New York Residence, in violation of New York Penal Law, Section 130.55.\nc. In or about 1996, when Minor Victim-2 was under the age of 18, MAXWELL provided Minor Victim-2 with an unsolicited massage in New Mexico, during which Minor Victim-2 was topless.\nd. Between in or about 1994 and in or about 1995, when Minor Victim-3 was under the age of 18, MAXWELL encouraged Minor Victim-3 to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Minor Victim-3 during those massages.\n(Title 18, United States Code, Section 371.)",
"position": "body"
},
{
"type": "printed",
"content": "COUNT TWO\n(Enticement of a Minor to Travel to Engage in Illegal Sex Acts)\nThe Grand Jury further charges:\n12. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within.",
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]
},
"additional_notes": "The document appears to be a legal indictment with no visible redactions or damage."
}

87
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{
"document_metadata": {
"page_number": "1",
"document_number": "54",
"date": "09/08/20",
"document_type": "court document",
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"full_text": "Case 1:20-cr-00330-AJN Document 54 Filed 09/08/20 Page 1 of 6\nHaddon, Morgan and Foreman, P.C\nJeffrey Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364 FX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com\nAugust 24, 2020\nVIA EMAIL\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007\nRe: Reply in Support of Request to Modify Protective Order (Under Seal)\nUnited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan,\nDefendant Ghislaine Maxwell filed a simple request: that she be permitted to disclose under seal (the \"Civil Litigation\") the fact that her adversary already handed over to the U.S. Attorney's Office pursuant to a subpoena.\nThe government proposes to keep in the dark about the fact and method of the disclosure. They claim the civil litigation is \"unrelated,\" that issuance of the subpoena was \"standard practice,\" and that disclosure will jeopardize an ongoing criminal investigation and \"permit dissemination of a vast swath of materials.\" Each of the government's arguments lack merit.\nThe Civil Litigation :\nFirst, the government claims the civil action is Resp. at 1. The assertion is frivolous.\n1 Ms. Maxwell has filed a letter motion which seeks leave to file this reply under seal, while providing the unredacted version to the government and the Court. This reply describes and discusses sealed materials and materials subject to the Protective Order in this case. Ms. Maxwell also simultaneously files under separate cover her proposed redactions to her Request to Modify Protective Order (Aug. 17, 2020), and this Reply, in accordance with the Court's Order of August 18, 2020 (Doc. 44).\nDOJ-OGR-00001763",
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"content": "Haddon, Morgan and Foreman, P.C\nJeffrey Pagliuca\n150 East 10th Avenue\nDenver, Colorado 80203\nPH 303.831.7364 FX 303.832.2628\nwww.hmflaw.com\njpagliuca@hmflaw.com",
"position": "header"
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{
"type": "printed",
"content": "August 24, 2020\nVIA EMAIL\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square\nNew York, NY 10007",
"position": "top"
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{
"type": "printed",
"content": "Re: Reply in Support of Request to Modify Protective Order (Under Seal)\nUnited States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
"position": "top"
},
{
"type": "printed",
"content": "Dear Judge Nathan,\nDefendant Ghislaine Maxwell filed a simple request: that she be permitted to disclose under seal (the \"Civil Litigation\") the fact that her adversary already handed over to the U.S. Attorney's Office pursuant to a subpoena.",
"position": "middle"
},
{
"type": "printed",
"content": "The government proposes to keep in the dark about the fact and method of the disclosure. They claim the civil litigation is \"unrelated,\" that issuance of the subpoena was \"standard practice,\" and that disclosure will jeopardize an ongoing criminal investigation and \"permit dissemination of a vast swath of materials.\" Each of the government's arguments lack merit.",
"position": "middle"
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{
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"content": "The Civil Litigation :\nFirst, the government claims the civil action is Resp. at 1. The assertion is frivolous.",
"position": "middle"
},
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"type": "printed",
"content": "1 Ms. Maxwell has filed a letter motion which seeks leave to file this reply under seal, while providing the unredacted version to the government and the Court. This reply describes and discusses sealed materials and materials subject to the Protective Order in this case. Ms. Maxwell also simultaneously files under separate cover her proposed redactions to her Request to Modify Protective Order (Aug. 17, 2020), and this Reply, in accordance with the Court's Order of August 18, 2020 (Doc. 44).",
"position": "bottom"
},
{
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"entities": {
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],
"reference_numbers": [
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]
},
"additional_notes": "The document appears to be a court filing with redactions. The quality is clear, but some information is obscured by black bars."
}

103
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{
"document_metadata": {
"page_number": "6",
"document_number": "93",
"date": "12/10/20",
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"full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 6 of 91\n\n1 which you discussed with Ms. Maxwell her right to be present\n2 and the indication of her knowing and voluntary waiver of that\n3 right provided on this form.\n4\n5 MR. COHEN: Yes, your Honor. We, given the press of\n6 time, we were not able to physically get the form to our\n7 client, but my partner Chris Everdell and I went through it\n8 with her, read it to her, and she gave us authorization to sign\n9 on her behalf and that's reflected on the form in the boxes\n10 where indicated, your Honor.\n11\n12 THE COURT: Okay. Ms. Maxwell, is that an accurate\n13 account of what occurred?\n14\n15 THE DEFENDANT: That is completely accurate, your\n16 Honor. Yes.\n17\n18 THE COURT: And you have had the form read to you or\n19 you have it physically now at this point?\n20\n21 THE DEFENDANT: That is correct, your Honor.\n22\n23 THE COURT: Okay. And you have had time to discuss it\n24 with your attorney?\n25\n26 THE DEFENDANT: I have, your Honor. Thank you.\n27\n28 THE COURT: Okay. And do you continue to wish to\n29 waive your right to be physically present and instead to\n30 proceed today by this videoconference proceeding?\n31\n32 THE DEFENDANT: Yes, your Honor.\n33\n34 THE COURT: All right. I do find a knowing and\n35 voluntary waiver of the right to be physically present for this\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001883",
"text_blocks": [
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"content": "which you discussed with Ms. Maxwell her right to be present and the indication of her knowing and voluntary waiver of that right provided on this form.",
"position": "main content"
},
{
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"content": "MR. COHEN: Yes, your Honor. We, given the press of time, we were not able to physically get the form to our client, but my partner Chris Everdell and I went through it with her, read it to her, and she gave us authorization to sign on her behalf and that's reflected on the form in the boxes where indicated, your Honor.",
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{
"type": "printed",
"content": "THE COURT: Okay. Ms. Maxwell, is that an accurate account of what occurred?",
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"content": "THE DEFENDANT: That is completely accurate, your Honor. Yes.",
"position": "main content"
},
{
"type": "printed",
"content": "THE COURT: And you have had the form read to you or you have it physically now at this point?",
"position": "main content"
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"type": "printed",
"content": "THE DEFENDANT: That is correct, your Honor.",
"position": "main content"
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"type": "printed",
"content": "THE COURT: Okay. And you have had time to discuss it with your attorney?",
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},
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"type": "printed",
"content": "THE DEFENDANT: I have, your Honor. Thank you.",
"position": "main content"
},
{
"type": "printed",
"content": "THE COURT: Okay. And do you continue to wish to waive your right to be physically present and instead to proceed today by this videoconference proceeding?",
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28
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"full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 12 of 91\n1 and federal law disclosure obligations.\n2 Go ahead, Ms. Moe.\n3 MS. MOE: Thank you, your Honor.\n4 With respect to the items that the government anticipates will be included in discovery in this case, we\n5 expect that those materials will include, among other items, search warrant returns, copies of search warrants, subpoena\n6 returns, including business records, photographs, electronically stored information from searches conducted on\n7 electronic devices. In addition, the materials with respect to the core of the case also include prior investigative files\n8 from another investigation in the Southern District of Florida among other items.\n9 With respect to the status of discovery, the government has begun preparing an initial production and are\n10 prepared to produce a first batch of discovery as soon as a protective order is entered by the court.\n11 With respect to the status of the proposed protective order, the government sent defense counsel a proposed\n12 protective order last week. We have touched base about the status of that with defense counsel, and they conveyed that\n13 they would like to continue reviewing and discussing it with the government, which we plan to do shortly after this\n14 conference, with an eye towards submitting a proposed protective order to the court as soon as possible. Following\n15 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001889",
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"content": "1 and federal law disclosure obligations.\n2 Go ahead, Ms. Moe.\n3 MS. MOE: Thank you, your Honor.\n4 With respect to the items that the government anticipates will be included in discovery in this case, we\n5 expect that those materials will include, among other items, search warrant returns, copies of search warrants, subpoena\n6 returns, including business records, photographs, electronically stored information from searches conducted on\n7 electronic devices. In addition, the materials with respect to the core of the case also include prior investigative files\n8 from another investigation in the Southern District of Florida among other items.\n9 With respect to the status of discovery, the government has begun preparing an initial production and are\n10 prepared to produce a first batch of discovery as soon as a protective order is entered by the court.\n11 With respect to the status of the proposed protective order, the government sent defense counsel a proposed\n12 protective order last week. We have touched base about the status of that with defense counsel, and they conveyed that\n13 they would like to continue reviewing and discussing it with the government, which we plan to do shortly after this\n14 conference, with an eye towards submitting a proposed protective order to the court as soon as possible. Following",
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{
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"full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 34 of 91\n1 And then, separately, the details about the cell phone, as the court noted, are contained in our brief and we submit that there could be no reason for wrapping a cell phone in tinfoil except for potentially to evade law enforcement, albeit foolishly and not well executed.\n2 THE COURT: All right. Go ahead\n3 MS. MOE: Thank you, your Honor.\n4 I believe I was discussing the defendant's finances, which underscore the concern about the defendant's ability to flee and about her questionable candor to the court. We submit there are concerns there for two reasons, your Honor.\n5 The first is that we learned that records relating -- reflecting to client information for a SWIFT bank include self-reported financial information from the defendant. In other words, when the account was opened, there were disclosures made about the defendant's finances. In those records, which are dated January 2019, the defendant's annual income is listed as ranging from $200,000 to approximately half a million dollars. And both her net worth and liquid assets are listed as ranging from $10 million and above.\n6 Second, as we noted in our reply, the defendant is the grantor of a trust account in the same SWIFT bank with assets of more than $4 million as of last month. Bank documents reflect that the trust has three trustees, one of whom has the authority to act independently. One of those trustees is a\n7 SOUTHERN DISTRICT REPORTERS, P.C.\n8 (212) 805-0300\n9 DOJ-OGR-00001911",
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"content": "1 And then, separately, the details about the cell phone, as the court noted, are contained in our brief and we submit that there could be no reason for wrapping a cell phone in tinfoil except for potentially to evade law enforcement, albeit foolishly and not well executed.\n2 THE COURT: All right. Go ahead\n3 MS. MOE: Thank you, your Honor.\n4 I believe I was discussing the defendant's finances, which underscore the concern about the defendant's ability to flee and about her questionable candor to the court. We submit there are concerns there for two reasons, your Honor.\n5 The first is that we learned that records relating -- reflecting to client information for a SWIFT bank include self-reported financial information from the defendant. In other words, when the account was opened, there were disclosures made about the defendant's finances. In those records, which are dated January 2019, the defendant's annual income is listed as ranging from $200,000 to approximately half a million dollars. And both her net worth and liquid assets are listed as ranging from $10 million and above.\n6 Second, as we noted in our reply, the defendant is the grantor of a trust account in the same SWIFT bank with assets of more than $4 million as of last month. Bank documents reflect that the trust has three trustees, one of whom has the authority to act independently. One of those trustees is a",
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67
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{
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"page_number": "9",
"document_number": "103",
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"full_text": "Case 1:20-cr-00330-AJN Document 103 Filed 12/23/20 Page 9 of 15\n\nmistaken. Prior to her arrest, Ms. Maxwell and her spouse had discussed the idea of getting a divorce as an additional way to create distance between Ms. Maxwell and her spouse to protect him from the terrible consequences of being associated with her. Nevertheless, in the weeks following the initial bail hearing, discussing divorce, which neither of them wanted in the first place. Nor was there any reason for her spouse to refrain from stepping forward as a co-signer. In sum, the government has offered nothing but unsupported innuendo to suggest that Ms. Maxwell's relationship with her spouse is not a powerful tie to this country. The government's assertion that Ms. Maxwell must not have a close relationship with is particularly callous and belied by the facts. (Gov. Mem. at 14). As her spouse explains, (Ex. A 12). B. Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All of Her and Her Spouse's Assets in Support of Her Bond The government's attempts to rebut the financial condition report are unavailing. Significantly, the government does not contest the accuracy of the report, nor the voluminous supporting documentation. In fact, the government has proffered nothing that calls into question the report's detailed account of Ms. Maxwell and her spouse's assets for the last five years, which addresses one of the Court's principal reasons for denying bail. Rather than question the report itself, the government attempts to argue that Ms. Maxwell deceived the Court and Pretrial Services about her assets. (Gov. Mem. at 22-23). 5 DOJ-OGR-00002215",
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"content": "mistaken. Prior to her arrest, Ms. Maxwell and her spouse had discussed the idea of getting a divorce as an additional way to create distance between Ms. Maxwell and her spouse to protect him from the terrible consequences of being associated with her. Nevertheless, in the weeks following the initial bail hearing, discussing divorce, which neither of them wanted in the first place. Nor was there any reason for her spouse to refrain from stepping forward as a co-signer. In sum, the government has offered nothing but unsupported innuendo to suggest that Ms. Maxwell's relationship with her spouse is not a powerful tie to this country. The government's assertion that Ms. Maxwell must not have a close relationship with is particularly callous and belied by the facts. (Gov. Mem. at 14). As her spouse explains, (Ex. A 12).",
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"content": "The government's attempts to rebut the financial condition report are unavailing. Significantly, the government does not contest the accuracy of the report, nor the voluminous supporting documentation. In fact, the government has proffered nothing that calls into question the report's detailed account of Ms. Maxwell and her spouse's assets for the last five years, which addresses one of the Court's principal reasons for denying bail. Rather than question the report itself, the government attempts to argue that Ms. Maxwell deceived the Court and Pretrial Services about her assets. (Gov. Mem. at 22-23).",
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"additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is mostly printed, with some redacted sections. There are no visible stamps or handwritten notes."
}

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{
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"full_text": "Case 1:20-cr-00330-AJN Document 122 Filed 01/25/21 Page 1 of 9\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n------------------------------------X\nUNITED STATES OF AMERICA,\n\nv.\n\n20 Cr. 330 (AJN)\n\nGHISLAINE MAXWELL,\n\nDefendant.\n------------------------------------X\n\nMEMORANDUM OF GHISLAINE MAXWELL\nIN SUPPORT OF HER MOTION TO DISMISS EITHER COUNT ONE OR COUNT\nTHREE OF THE SUPERSEDING INDICTMENT AS MULTIPLICITOUS\n\nJeffrey S. Pagliuca\nLaura A. Menninger\nHADDON, MORGAN & FOREMAN P.C.\n150 East 10th Avenue\nDenver, CO 80203\nPhone: 303-831-7364\n\nMark S. Cohen\nChristian R. Everdell\nCOHEN & GRESSER LLP\n800 Third Avenue New\nYork, NY 10022\nPhone: 212-957-7600\n\nBobbi C. Sternheim\nLaw Offices of Bobbi C. Sternheim\n33 West 19th Street - 4th Floor\nNew York, NY 10011\nPhone: 212-243-1100\n\nAttorneys for Ghislaine Maxwell\n\nDOJ-OGR-00002300",
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"content": "Jeffrey S. Pagliuca\nLaura A. Menninger\nHADDON, MORGAN & FOREMAN P.C.\n150 East 10th Avenue\nDenver, CO 80203\nPhone: 303-831-7364",
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"additional_notes": "The document appears to be a court filing in the case of United States v. Ghislaine Maxwell. The document is a memorandum in support of a motion to dismiss certain counts of the superseding indictment. The document is well-formatted and legible."
}

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{
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"full_text": "Case 1:20-cr-00330-AJN Document 136 Filed 02/04/21 Page 18 of 27\ndifferent from the first question because it included the phrase\n\nAgain, the question was objected to. After much back and forth, the examiner asked the question giving rise to the second alleged instance of perjury: \"List all the people under the age of 18 that you interacted with at any of Jeffrey's properties?\"\n\nThis question was almost the same as the first demand for a \"list,\" but instead of\n\nthe examiner substituted the amorphous, ambiguous phrase \"interacted with.\" Ms. Maxwell had already answered that she could not \"make a list.\" The question was improper for the additional reason that \"the taking of an oral deposition pursuant to Fed. R. Civ. P. Rule 26, should not be converted in effect into an interrogatory procedure (Rule 33) or an inspection procedure (Rule 34)...\" Deep S. Oil Co of Tex v. Metro. Life Ins Co., 25 F.R.D. 81, 82 (S.D.N.Y. 1959).\n\nC. Count Six\n\nThe alleged perjury in Count Six can be broken down into three topics separated by dozens of pages of objections, argument, and colloquy (including the examiner's refusal to allow Ms. Maxwell to take a bathroom break). The topics involved\n\nAs in Count Five, the Government has selectively omitted context and objections. Exact quotes, in context, are set forth below, followed by analysis of the infirmities in each line of questioning:\n\n1. Questions About",
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"content": "different from the first question because it included the phrase\n\nAgain, the question was objected to. After much back and forth, the examiner asked the question giving rise to the second alleged instance of perjury: \"List all the people under the age of 18 that you interacted with at any of Jeffrey's properties?\"\n\nThis question was almost the same as the first demand for a \"list,\" but instead of\n\nthe examiner substituted the amorphous, ambiguous phrase \"interacted with.\" Ms. Maxwell had already answered that she could not \"make a list.\" The question was improper for the additional reason that \"the taking of an oral deposition pursuant to Fed. R. Civ. P. Rule 26, should not be converted in effect into an interrogatory procedure (Rule 33) or an inspection procedure (Rule 34)...\" Deep S. Oil Co of Tex v. Metro. Life Ins Co., 25 F.R.D. 81, 82 (S.D.N.Y. 1959).",
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"content": "The alleged perjury in Count Six can be broken down into three topics separated by dozens of pages of objections, argument, and colloquy (including the examiner's refusal to allow Ms. Maxwell to take a bathroom break). The topics involved",
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"additional_notes": "The document appears to be a court filing related to a case involving Ms. Maxwell and Jeffrey. The text includes redactions and references to specific court rules and precedents. The document is likely a legal brief or memorandum."
}

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"full_text": "Case 1:20-cr-00330-AJN Document 140 Filed 02/04/21 Page 4 of 22 Constitutional Provisions U.S. CONST. amend. IV .............................................................................. passim U.S. CONST. amend. V .............................................................................. passim iii DOJ-OGR-00002552",
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"additional_notes": "The document appears to be a court filing with references to the U.S. Constitution. The content is mostly citations and references to constitutional amendments."
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{
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"full_text": "Case 1:20-cr-00330-AJN Document 142 Filed 02/04/21 Page 17 of 38\ndiscovery demonstrates that . Exh. G . As the NPA reflects, Epstein's objective in negotiating the NPA was to obtain a global resolution that would, among other things, provide maximum protection for any alleged co-conspirators, in significant part to minimize the likelihood that Epstein could be subpoenaed as a potential witness and have to testify under oath. NPA at 2 (noting that Epstein \"seeks to resolve globally his state and federal criminal liability\"). The NPA makes clear that its identification of four \"potential co-conspirators\" by name—Kellen, Ross, Groff, and Marcinkova—was not intended to limit the immunity provision to those four individuals (\"but not limited to\"), and we understand that those individuals . See Exh. H . ARGUMENT\nThe Supreme Court has long recognized the enforceability of plea agreements. \"[W]hen a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can be said to be part of the inducement or consideration, such promise must be fulfilled.\"\nSantobello v. New York, 404 U.S. 257, 262 (1971).\nWhile plea agreements are interpreted under basic principles of contract law, the Second Circuit has noted that \"plea agreements . . . are unique contracts in which special due process concerns for fairness and the adequacy of procedural safeguards obtain.\" United States v. Ready, 82 F.3d 551, 558 (2d Cir. 1996) (internal quotation marks omitted); see also United States v. Mozer, 828 F. Supp. 208, 215 (S.D.N.Y. 1993) (\"[A] prosecutor entering into a plea bargain",
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"content": "discovery demonstrates that . Exh. G . As the NPA reflects, Epstein's objective in negotiating the NPA was to obtain a global resolution that would, among other things, provide maximum protection for any alleged co-conspirators, in significant part to minimize the likelihood that Epstein could be subpoenaed as a potential witness and have to testify under oath. NPA at 2 (noting that Epstein \"seeks to resolve globally his state and federal criminal liability\"). The NPA makes clear that its identification of four \"potential co-conspirators\" by name—Kellen, Ross, Groff, and Marcinkova—was not intended to limit the immunity provision to those four individuals (\"but not limited to\"), and we understand that those individuals . See Exh. H .",
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"content": "The Supreme Court has long recognized the enforceability of plea agreements. \"[W]hen a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can be said to be part of the inducement or consideration, such promise must be fulfilled.\"\nSantobello v. New York, 404 U.S. 257, 262 (1971).\nWhile plea agreements are interpreted under basic principles of contract law, the Second Circuit has noted that \"plea agreements . . . are unique contracts in which special due process concerns for fairness and the adequacy of procedural safeguards obtain.\" United States v. Ready, 82 F.3d 551, 558 (2d Cir. 1996) (internal quotation marks omitted); see also United States v. Mozer, 828 F. Supp. 208, 215 (S.D.N.Y. 1993) (\"[A] prosecutor entering into a plea bargain",
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"additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. The text is mostly printed, with some redacted sections. The document includes citations to legal cases and references to exhibits."
}

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"full_text": "Case 1:20-cr-00330-AJN Document 168 Filed 03/18/21 Page 1 of 5\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\nUnited States of America,\n\n-v-\n\nGhislaine Maxwell,\nDefendant.\n\n20-CR-330 (AJN)\n\nORDER\n\nALISON J. NATHAN, District Judge:\n\nOn February 26, 2021, the Government filed its omnibus memorandum of law opposing Defendants' twelve pre-trial motions. It filed the brief, along with the corresponding exhibits, under temporary seal pending the Court's resolution of its request to redact sensitive or confidential information. See Dkt. No. 162. On March 9, 2021, the Defendant objected to certain of the redactions that the Government had proposed, and she proposed additional redactions. Having considered the parties' respective positions, the Court will grant the Government's requests for redactions and sealing, as well as the Defendant's additional redaction requests, with the exceptions discussed below.\n\nTo begin with, the Court's reasoning is guided by the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the documents in question are \"judicial documents;\" (ii) assess the weight of the common law presumption of access to the materials; and (iii) balance competing considerations against the presumption of access. Id. at 119-20. \"Such countervailing factors include but are not limited to 'the danger of impairing law enforcement or judicial efficiency' and 'the privacy interests of those resisting disclosure.'\" Id. at 120 (quoting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) (\"Amodeo II\")).\n\n1\n\nDOJ-OGR-00002762",
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"content": "On February 26, 2021, the Government filed its omnibus memorandum of law opposing Defendants' twelve pre-trial motions. It filed the brief, along with the corresponding exhibits, under temporary seal pending the Court's resolution of its request to redact sensitive or confidential information. See Dkt. No. 162. On March 9, 2021, the Defendant objected to certain of the redactions that the Government had proposed, and she proposed additional redactions. Having considered the parties' respective positions, the Court will grant the Government's requests for redactions and sealing, as well as the Defendant's additional redaction requests, with the exceptions discussed below.",
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"content": "To begin with, the Court's reasoning is guided by the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Under this test, the Court must: (i) determine whether the documents in question are \"judicial documents;\" (ii) assess the weight of the common law presumption of access to the materials; and (iii) balance competing considerations against the presumption of access. Id. at 119-20. \"Such countervailing factors include but are not limited to 'the danger of impairing law enforcement or judicial efficiency' and 'the privacy interests of those resisting disclosure.'\" Id. at 120 (quoting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) (\"Amodeo II\")).",
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}

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"full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 226 of 239 available grand jury that day, due to the global pandemic68—“was a deviation from the established practice of indicting defendants in the division where the offense is alleged to have occurred and where the case will be tried.” (Def. Mot. 9 at 2). Because the offense is alleged to have occurred in the “Manhattan Division” and the defendant assumes that her jury trial will occur there too, she argues that the “appropriate comparison,” for the purpose of her fair cross-section claim, “is therefore between the Manhattan Division and the qualified wheel for White Plains.” (Def. Mot. 9 at 6). This premise is faulty. “It is well-settled that neither the jury selection statute nor the Constitution requires that jurors be drawn from an entire district.” Bahna, 68 F.3d at 24 (collecting cases); see also United States v. Plaza-Andrades, 507 F. App’x 22, 26 (2d Cir. 2013) (“[O]ur precedent makes clear that the Sixth Amendment does not entitle a defendant to be tried in a geographic location any more 68 This case was indicted on June 29, 2020, on which date the grand jury sitting in White Plains was the only available grand jury in the District. Beginning on or about June 25, 2020, grand jury quorums returned in Manhattan, but with substantially less availability than before the pandemic. As a result, the Government has sought indictments from grand juries sitting in White Plains and Manhattan, as availability permits. In this instance, the Government was prepared to indict on June 29, 2020, and the only grand jury available in this District on that day sat at White Plains. The global pandemic’s effect on grand jury availability continues to evolve, but at no point have grand juries in White Plains or Manhattan resumed normal activity. The defendant speculates that the Government sought an indictment on June 29, 2020 because of some arbitrary desire to arrest the defendant on July 2, 2020, one year to the day after a grand jury returned a sealed indictment charging Jeffrey Epstein with federal crimes on July 2, 2019. (See, e.g., Def. Mot. 9 at 1, 8). Setting aside the silliness of marking the anniversary of an indictment’s return, as opposed to the anniversary of the arrest itself, which took place on July 6, 2019, there is no reality in the defense’s conspiracy theories. As the defense knows full well, the Government attempted to locate and arrest the defendant on July 1, 2020 but was unable to her location until obtaining cellphone location data identifying her location and enabling her arrest on July 2, 2020. The defense knows this because they have the warrant application that the Government submitted on July 1, 2020 for the defendant’s cellphone location information, in which the Government stated that it had been unable to confirm the defendant’s location. In other words, the Government indicted the defendant as soon as it was prepared to present the evidence it had gathered to a grand jury, and the Government arrested the defendant as soon as it was able to locate her after obtaining that indictment. 199 DOJ-OGR-00003160",
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"content": "available grand jury that day, due to the global pandemic68—“was a deviation from the established practice of indicting defendants in the division where the offense is alleged to have occurred and where the case will be tried.” (Def. Mot. 9 at 2). Because the offense is alleged to have occurred in the “Manhattan Division” and the defendant assumes that her jury trial will occur there too, she argues that the “appropriate comparison,” for the purpose of her fair cross-section claim, “is therefore between the Manhattan Division and the qualified wheel for White Plains.” (Def. Mot. 9 at 6). This premise is faulty. “It is well-settled that neither the jury selection statute nor the Constitution requires that jurors be drawn from an entire district.” Bahna, 68 F.3d at 24 (collecting cases); see also United States v. Plaza-Andrades, 507 F. App’x 22, 26 (2d Cir. 2013) (“[O]ur precedent makes clear that the Sixth Amendment does not entitle a defendant to be tried in a geographic location any more",
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"content": "68 This case was indicted on June 29, 2020, on which date the grand jury sitting in White Plains was the only available grand jury in the District. Beginning on or about June 25, 2020, grand jury quorums returned in Manhattan, but with substantially less availability than before the pandemic. As a result, the Government has sought indictments from grand juries sitting in White Plains and Manhattan, as availability permits. In this instance, the Government was prepared to indict on June 29, 2020, and the only grand jury available in this District on that day sat at White Plains. The global pandemic’s effect on grand jury availability continues to evolve, but at no point have grand juries in White Plains or Manhattan resumed normal activity.",
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"content": "The defendant speculates that the Government sought an indictment on June 29, 2020 because of some arbitrary desire to arrest the defendant on July 2, 2020, one year to the day after a grand jury returned a sealed indictment charging Jeffrey Epstein with federal crimes on July 2, 2019. (See, e.g., Def. Mot. 9 at 1, 8). Setting aside the silliness of marking the anniversary of an indictment’s return, as opposed to the anniversary of the arrest itself, which took place on July 6, 2019, there is no reality in the defense’s conspiracy theories. As the defense knows full well, the Government attempted to locate and arrest the defendant on July 1, 2020 but was unable to her location until obtaining cellphone location data identifying her location and enabling her arrest on July 2, 2020. The defense knows this because they have the warrant application that the Government submitted on July 1, 2020 for the defendant’s cellphone location information, in which the Government stated that it had been unable to confirm the defendant’s location. In other words, the Government indicted the defendant as soon as it was prepared to present the evidence it had gathered to a grand jury, and the Government arrested the defendant as soon as it was able to locate her after obtaining that indictment.",
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"full_text": "Case 1:20-cr-00330-PAE Document 204-5 Filed 04/16/21 Page 1 of 9\nP. Skinner 2/29/16\nBrad Edwards\nStan Pottinger\nA. Kramer (notes)\nBE - rep. Virginia Roberts\nSP - rep. Virginia\nLong history of litigation\nBE\nFirst inv. into Jeffrey Epstein was done by Coral Palmer Beach PD (~2005)\nrounded up approx. 24 girls related by JE\nrepresented about 10 girls\nJE's MO - w/ adults they'd tell 13 yr. old girl 'came to rich guy's house to give paid massage. JE naked - starts as massage & ultimate demand of sex acts (if you want $, do $). After paid 200/300 - then offered 800-300 finders fee. Victims recruited other victims. Mother complained & involved PD.\nPD turned case over to FBI & USAP. Most of girls (approx. 40+) in FL. No flight (logs).\nIssued CT subpoenas Epstein + 4 named co-conspirators\nEntered into a nina plea for state ct. to 2001-2007 prostitution minor & prostitution immunity\nfed. pros. for sex crimes comm. in FL btw 2001 - 2007\nJen Lefcourt, Jay Lefkowitz, Ken Starr, Roy Black Epstein\nMartin Weinberg, Gary Lewin - never Jem shared (ourselves)\nSD FL - at Palm Beach, Mariz Viagra\nLimited to FL in plea",
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"additional_notes": "The document appears to be a handwritten note related to a court case involving Jeffrey Epstein. The handwriting is mostly legible, but some words are difficult to decipher. The document includes a header with case information and a footer with a document control number."
}

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"full_text": "Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 19 of 21\nConfidential\nPage 112\n1 G. Maxwell - Confidential\n2 ever see ?\n3 A. I don't recall ever seeing her.\n4 Q.\n5 A.\n6 Q. Did ever engage in any\n7 sexual activity with Mr. Epstein?\n8 A. I wouldn't know. I would assume\n9 not, but I don't know.\n10 Q. Do you have any reason to believe\n11 that Mr. Epstein engaged in any sexual\n12 activity with ?\n13 MR. PAGLIUCA: Objection to form\n14 and foundation.\n15 A. I wouldn't know.\n16 Q. Did you ever give a massage to\n17 anyone other than Mr. Epstein at any of Mr.\n18 Epstein's properties?\n19 A. First of all, I never said I gave\n20 Mr. Epstein a massage.\n21 Q. I will ask that question if you\n22 want, but I was focusing on people other than\n23 Mr. Epstein right now.\n24 A. I don't give massages.",
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53
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{
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"full_text": "Case 1:20-cr-00330-PAE Document 208 Filed 04/16/21 Page 5 of 16\n\nThe government misunderstands both the law and the facts related to the Giuffre v. Maxwell defamation litigation. Although the government aspires to present “a more streamlined presentation” at trial (Resp. 118 fn. 46), it is unlikely to meet this goal. What follows is a very truncated discussion of some of the facts to place the questions and answers in Ms. Maxwell’s depositions from that civil action in context:\n\nI. The Defamation Action\n\nIn 2008, two alleged Epstein victims brought an action under the Crime Victims’ Rights Act (CVRA) against the United States government purporting to challenge Epstein’s plea agreement. They alleged the government violated their CVRA rights by entering into the agreement. Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA action, claiming she too had her CVRA rights violated by the government. On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. The issue presented in her joinder motion was narrow: whether she should be permitted to join the CVRA action as a party under Federal Rule of Civil Procedure 21, specifically, whether she was a “known victim” of Mr. Epstein and the Government owed them CVRA duties,” Ex. L at 5. Yet, the court noted, “the bulk of the [motion] consists of copious factual details that [Giuffre] and [her co-movant] ‘would prove . . . if allowed to join.’” Id. (brackets omitted). Ms. Giuffre gratuitously included provocative and “lurid details” of her alleged sexual activities as an alleged victim of sexual trafficking. Id.\n\nAt the time they filed the motion, Ms. Giuffre and her lawyers knew that the media had been following the Epstein criminal case and the CVRA action. While they deliberately filed the motion without disclosing Ms. Giuffre’s name, claiming the need for privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they filed the motion publicly.\n\nAs the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d] several",
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{
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"full_text": "Case 1:20-cr-00330-PAE Document 212 Filed 04/16/21 Page 16 of 20\n\nMaxwell with perjury.3 There are compelling reasons, therefore, to think the government and Boies Schiller collaborated and that Boies Schiller's conduct was in part at the government's behest.\n\nThe record in the Giuffre case preceding the first deposition supports this conclusion as well. Based on Giuffre's claim of an ongoing investigation, Maxwell requested, prior to her deposition, that Giuffre disclose any alleged \"on-going criminal investigation by law enforcement\" or alternatively to stay the action pending completion of any such investigation. Ex. A. In part, Maxwell needed information concerning any such investigation to assess \"the impact on any 5th Amendment privilege.\" Ex. A, p 3. The district court declined to afford Ms. Maxwell the requested relief. Ex. B.\n\nThe day before Maxwell's April 2016 deposition, however, Judge Sweet ordered that \"[a]ny materials that [Giuffre] has with respect to any criminal investigations will be turned over [by Giuffre] except for any statements made by [Giuffre] to law enforcement authority.\" Ex. B, p 21. Maxwell had in fact served a discovery request on Boies Schiller for any such documents, yet Giuffre produced no such materials, and the deposition proceeded as scheduled the next day.\n\nIn reliance on the Protective Order, which included no exception for any law enforcement need or subpoena and based on Giuffre's failure to disclose any \"ongoing criminal investigation,\" Maxwell did not assert her Fifth Amendment privilege against self-incrimination during that deposition and testified truthfully.\n\nAs explained in Maxwell's Pretrial Motion No. 3 and the Reply in Support Thereof, the government has now disclosed several documents \"with respect to any criminal investigations\"\n\n3 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020), https://www.nydailynews.com/new-york/ny-jeffrey-epstein-maxwell-case-20201013-jmzh17zdrzdgrbbs7yc6bfnszu-story.html.",
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"content": "Maxwell with perjury.3 There are compelling reasons, therefore, to think the government and Boies Schiller collaborated and that Boies Schiller's conduct was in part at the government's behest.",
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},
{
"type": "printed",
"content": "The record in the Giuffre case preceding the first deposition supports this conclusion as well. Based on Giuffre's claim of an ongoing investigation, Maxwell requested, prior to her deposition, that Giuffre disclose any alleged \"on-going criminal investigation by law enforcement\" or alternatively to stay the action pending completion of any such investigation. Ex. A. In part, Maxwell needed information concerning any such investigation to assess \"the impact on any 5th Amendment privilege.\" Ex. A, p 3. The district court declined to afford Ms. Maxwell the requested relief. Ex. B.",
"position": "middle"
},
{
"type": "printed",
"content": "The day before Maxwell's April 2016 deposition, however, Judge Sweet ordered that \"[a]ny materials that [Giuffre] has with respect to any criminal investigations will be turned over [by Giuffre] except for any statements made by [Giuffre] to law enforcement authority.\" Ex. B, p 21. Maxwell had in fact served a discovery request on Boies Schiller for any such documents, yet Giuffre produced no such materials, and the deposition proceeded as scheduled the next day.",
"position": "middle"
},
{
"type": "printed",
"content": "In reliance on the Protective Order, which included no exception for any law enforcement need or subpoena and based on Giuffre's failure to disclose any \"ongoing criminal investigation,\" Maxwell did not assert her Fifth Amendment privilege against self-incrimination during that deposition and testified truthfully.",
"position": "middle"
},
{
"type": "printed",
"content": "As explained in Maxwell's Pretrial Motion No. 3 and the Reply in Support Thereof, the government has now disclosed several documents \"with respect to any criminal investigations\"",
"position": "middle"
},
{
"type": "printed",
"content": "3 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020), https://www.nydailynews.com/new-york/ny-jeffrey-epstein-maxwell-case-20201013-jmzh17zdrzdgrbbs7yc6bfnszu-story.html.",
"position": "footer"
},
{
"type": "printed",
"content": "11",
"position": "footer"
},
{
"type": "printed",
"content": "DOJ-OGR-00003790",
"position": "footer"
}
],
"entities": {
"people": [
"Maxwell",
"Giuffre",
"Jeffrey Epstein",
"Ghislaine Maxwell",
"Stephen Rex Brown"
],
"organizations": [
"Boies Schiller",
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],
"locations": [
"Manhattan"
],
"dates": [
"April 2016",
"Oct. 13, 2020",
"04/16/21"
],
"reference_numbers": [
"1:20-cr-00330-PAE",
"Document 212",
"Ex. A",
"Ex. B",
"Pretrial Motion No. 3",
"DOJ-OGR-00003790"
]
},
"additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document includes references to other court documents and news articles."
}

114
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{
"document_metadata": {
"page_number": "2",
"document_number": "LL7",
"date": "May 11, 2021",
"document_type": "Letter",
"has_handwriting": true,
"has_stamps": false
},
"full_text": "Case 1:20-cv-03003-PAE Document LL7 Filed 05/11/21 Page 2 of 2\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\nORGEOIRDO 50\n\nThe Honorable Judge Paul A. Engelmayer\n\nUnited States District Judge\n\nThe Court will be in recess from June 29, 2021 through July 12, 2021. The parties are directed to submit a joint status letter on July 13, 2021, and to appear for a status conference on July 14, 2021, at 10:00 a.m. The parties are also directed to submit a proposed briefing schedule for the anticipated dispositive motions by July 20, 2021.\n\nThe parties have consented to proceed before a magistrate judge for all purposes, including trial.\n\nThe Court has received the parties' joint letter dated May 11, 2021, and has reviewed the parties' proposed case management plan.\n\nThe Court has reviewed the parties' joint letter dated May 11, 2021, and has approved the parties' proposed case management plan.\n\nIT IS HEREBY ORDERED that the parties shall file a joint status letter on July 13, 2021, and shall appear for a status conference on July 14, 2021, at 10:00 a.m.\n\nIT IS FURTHER ORDERED that the parties shall submit a proposed briefing schedule for the anticipated dispositive motions by July 20, 2021.\n\nSO ORDERED.\n\n/s/ Paul A. Engelmayer\n\nPaul A. Engelmayer\nUnited States District Judge\n\nDated: May 11, 2021\nNew York, New York\n\nDOJ-OGR-00004122",
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{
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},
{
"type": "printed",
"content": "The Honorable Judge Paul A. Engelmayer United States District Judge",
"position": "middle"
},
{
"type": "printed",
"content": "The Court will be in recess from June 29, 2021 through July 12, 2021. The parties are directed to submit a joint status letter on July 13, 2021, and to appear for a status conference on July 14, 2021, at 10:00 a.m. The parties are also directed to submit a proposed briefing schedule for the anticipated dispositive motions by July 20, 2021.",
"position": "middle"
},
{
"type": "printed",
"content": "The parties have consented to proceed before a magistrate judge for all purposes, including trial.",
"position": "middle"
},
{
"type": "printed",
"content": "The Court has received the parties' joint letter dated May 11, 2021, and has reviewed the parties' proposed case management plan.",
"position": "middle"
},
{
"type": "printed",
"content": "The Court has reviewed the parties' joint letter dated May 11, 2021, and has approved the parties' proposed case management plan.",
"position": "middle"
},
{
"type": "printed",
"content": "IT IS HEREBY ORDERED that the parties shall file a joint status letter on July 13, 2021, and shall appear for a status conference on July 14, 2021, at 10:00 a.m.",
"position": "middle"
},
{
"type": "printed",
"content": "IT IS FURTHER ORDERED that the parties shall submit a proposed briefing schedule for the anticipated dispositive motions by July 20, 2021.",
"position": "middle"
},
{
"type": "printed",
"content": "SO ORDERED.",
"position": "middle"
},
{
"type": "handwritten",
"content": "/s/ Paul A. Engelmayer",
"position": "middle"
},
{
"type": "printed",
"content": "Paul A. Engelmayer United States District Judge",
"position": "middle"
},
{
"type": "printed",
"content": "Dated: May 11, 2021 New York, New York",
"position": "bottom"
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{
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"content": "DOJ-OGR-00004122",
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],
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"July 12, 2021",
"July 13, 2021",
"July 14, 2021",
"July 20, 2021"
],
"reference_numbers": [
"Case 1:20-cv-03003-PAE",
"Document LL7",
"DOJ-OGR-00004122"
]
},
"additional_notes": "The document is a court order from the United States District Court for the Southern District of New York. It is signed by Judge Paul A. Engelmayer and dated May 11, 2021. The document appears to be a standard court order, with no unusual or notable features."
}

78
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@ -0,0 +1,78 @@
{
"document_metadata": {
"page_number": "6",
"document_number": "28509",
"date": "07/06/21",
"document_type": "court document",
"has_handwriting": false,
"has_stamps": false
},
"full_text": "Case 1:19-cv-03339-RWS Document 28509 Filed 07/06/21 Page 6 of 112\n\nPutting aside the admissibility of this testimony, it appears that both men were involved in the investigation of Mr. Epstein and are expected to testify about their investigation. Plaintiff's allegations were not a part of their investigation, which took place years after Plaintiff left the country. Moreover, their investigation did not involve Ms. Maxwell. Again, such duplicative and irrelevant deposition testimony speaks to the intended purpose of the ten-deposition limit, not a reason to exceed that limit.\n\nThe same holds true for Nadia Marcinkova, Sarah Kellen (a/k/a Sarah Kensigton or Sarah Vickers) and Jeffrey Epstein, each of whom Plaintiff anticipates will not respond to questions and invoke their Fifth Amendment right. As discussed above, such invocation has no bearing on the issues in this matter. Moreover, it is obviously cumulative and duplicative.\n\nPlaintiff also identifies Rinaldo Rizzo and Jean Luc Brunel but fails to provide any information from which Ms. Maxwell or the Court could identify the subject matter of their expected testimony. Thus, it is unclear how these individuals have information that differs from or would add to the other proposed deponents. It is the Plaintiff's burden to explain to the Court why these depositions should be permitted if they exceed the presumptive limit, why the information would not be cumulative, and its relevance to the important issues in the action, or the importance of the discovery in resolving those issues. She simply fails to provide any information by which the Court can assess these factors, and thus should not be permitted to exceed the deposition limit based on her proffer.\n\nIII. THE TESTIMONY SOUGHT IS IRRELEVANT TO THIS SINGLE COUNT DEFAMATION CASE\n\nThis case is a simple defamation case. Plaintiff, through her counsel, filed a pleading making certain claims regarding \"Jane Doe No. #3\" - the Plaintiff - and her alleged",
"text_blocks": [
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"content": "Case 1:19-cv-03339-RWS Document 28509 Filed 07/06/21 Page 6 of 112",
"position": "header"
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{
"type": "printed",
"content": "Putting aside the admissibility of this testimony, it appears that both men were involved in the investigation of Mr. Epstein and are expected to testify about their investigation. Plaintiff's allegations were not a part of their investigation, which took place years after Plaintiff left the country. Moreover, their investigation did not involve Ms. Maxwell. Again, such duplicative and irrelevant deposition testimony speaks to the intended purpose of the ten-deposition limit, not a reason to exceed that limit.",
"position": "top"
},
{
"type": "printed",
"content": "The same holds true for Nadia Marcinkova, Sarah Kellen (a/k/a Sarah Kensigton or Sarah Vickers) and Jeffrey Epstein, each of whom Plaintiff anticipates will not respond to questions and invoke their Fifth Amendment right. As discussed above, such invocation has no bearing on the issues in this matter. Moreover, it is obviously cumulative and duplicative.",
"position": "middle"
},
{
"type": "printed",
"content": "Plaintiff also identifies Rinaldo Rizzo and Jean Luc Brunel but fails to provide any information from which Ms. Maxwell or the Court could identify the subject matter of their expected testimony. Thus, it is unclear how these individuals have information that differs from or would add to the other proposed deponents. It is the Plaintiff's burden to explain to the Court why these depositions should be permitted if they exceed the presumptive limit, why the information would not be cumulative, and its relevance to the important issues in the action, or the importance of the discovery in resolving those issues. She simply fails to provide any information by which the Court can assess these factors, and thus should not be permitted to exceed the deposition limit based on her proffer.",
"position": "middle"
},
{
"type": "printed",
"content": "III. THE TESTIMONY SOUGHT IS IRRELEVANT TO THIS SINGLE COUNT DEFAMATION CASE",
"position": "middle"
},
{
"type": "printed",
"content": "This case is a simple defamation case. Plaintiff, through her counsel, filed a pleading making certain claims regarding \"Jane Doe No. #3\" - the Plaintiff - and her alleged",
"position": "bottom"
},
{
"type": "printed",
"content": "6",
"position": "footer"
},
{
"type": "printed",
"content": "DOJ-OGR-00004209",
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],
"entities": {
"people": [
"Mr. Epstein",
"Ms. Maxwell",
"Nadia Marcinkova",
"Sarah Kellen",
"Sarah Kensigton",
"Sarah Vickers",
"Jeffrey Epstein",
"Rinaldo Rizzo",
"Jean Luc Brunel",
"Jane Doe No. #3"
],
"organizations": [],
"locations": [],
"dates": [
"07/06/21"
],
"reference_numbers": [
"1:19-cv-03339-RWS",
"28509",
"DOJ-OGR-00004209"
]
},
"additional_notes": "The document appears to be a court filing related to a defamation case. The text is printed and there are no visible stamps or handwritten notes. The document is page 6 of 112."
}

62
results/IMAGES002/DOJ-OGR-00004211.json Normal file
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@ -0,0 +1,62 @@
{
"document_metadata": {
"page_number": "8",
"document_number": "28589",
"date": "05/09/21",
"document_type": "court document",
"has_handwriting": false,
"has_stamps": false
},
"full_text": "occurred or that they occurred with the people she claims to have been involved. Rather, each witness identified as being able to provide their observations regarding \"other\" allegedly underage girls, their own personal experience,6 or beliefs about Plaintiff's credibility. None of this is relevant. This is not a case about Jeffery Epstein or the alleged \"modus operandi of the Epstein organization.\" This is a simple case of if Ms. Maxwell's denial of the allegations made by Plaintiff about Plaintiff's own interactions with Maxwell was defamatory, and if Ms. Maxwell acted with actual malice in issuing the denial. Plaintiff's attempt to amplify this proceeding into something broader should not be condoned.\n\nBecause the evidence sought is nothing more than extraneous inadmissible \"circumstantial evidence\"7 irrelevant to proving the essential elements of the claim, \"the burden or expense of the proposed discovery outweighs its likely benefit, considering the needs of the case, the parties' resources, the importance of the issues at stake in the action, and the importance of the discovery in resolving the issues.\" Atkinson, 2009 WL 890682, at *1. As such, the request for the additional depositions should be denied.\n\nWHEREFORE, Ms. Maxwell requests that the Motion to permit in excess of the presumptive ten deposition limit be denied; alternatively, if in excess of ten depositions are permitted, Ms. Maxwell requests that Plaintiff be required to pay all costs and attorney's fees\n\n6 The information sought is also inadmissible. Plaintiff seeks testimony from witness who she claims will testify to experience similar to her stories and this will Motion at 15-16. Such evidence is prohibited by FRE 404(b), which states \"Evidence of a crime, wrong, or other act is not admissible to prove a person's character in order to show that on a particular occasion the person acted in accordance with the character.\" Furthermore, no other witness has claimed as Plaintiff does that Ghislaine Maxwell sexually abused them, sexually trafficked them, or that she partook in daily sex with any underage girls. Plaintiff's claim stands in isolation because it is fictional.\n\n7 This \"circumstantial evidence\" has no bearing on the truthfulness of the stories published by Plaintiff. It is equally likely to show that Plaintiff became aware of the allegations of others and decided to hop on the band wagon. She then made up similar claims for the purpose of getting paid hundreds of thousands of dollars by the media for publicizing her allegations and identifying well know public figures whose names she has seen documents that she reviewed or other stories she had read.\n\n8",
"text_blocks": [
{
"type": "printed",
"content": "occurred or that they occurred with the people she claims to have been involved. Rather, each witness identified as being able to provide their observations regarding \"other\" allegedly underage girls, their own personal experience,6 or beliefs about Plaintiff's credibility. None of this is relevant. This is not a case about Jeffery Epstein or the alleged \"modus operandi of the Epstein organization.\" This is a simple case of if Ms. Maxwell's denial of the allegations made by Plaintiff about Plaintiff's own interactions with Maxwell was defamatory, and if Ms. Maxwell acted with actual malice in issuing the denial. Plaintiff's attempt to amplify this proceeding into something broader should not be condoned.",
"position": "top"
},
{
"type": "printed",
"content": "Because the evidence sought is nothing more than extraneous inadmissible \"circumstantial evidence\"7 irrelevant to proving the essential elements of the claim, \"the burden or expense of the proposed discovery outweighs its likely benefit, considering the needs of the case, the parties' resources, the importance of the issues at stake in the action, and the importance of the discovery in resolving the issues.\" Atkinson, 2009 WL 890682, at *1. As such, the request for the additional depositions should be denied.",
"position": "middle"
},
{
"type": "printed",
"content": "WHEREFORE, Ms. Maxwell requests that the Motion to permit in excess of the presumptive ten deposition limit be denied; alternatively, if in excess of ten depositions are permitted, Ms. Maxwell requests that Plaintiff be required to pay all costs and attorney's fees",
"position": "middle"
},
{
"type": "printed",
"content": "6 The information sought is also inadmissible. Plaintiff seeks testimony from witness who she claims will testify to experience similar to her stories and this will Motion at 15-16. Such evidence is prohibited by FRE 404(b), which states \"Evidence of a crime, wrong, or other act is not admissible to prove a person's character in order to show that on a particular occasion the person acted in accordance with the character.\" Furthermore, no other witness has claimed as Plaintiff does that Ghislaine Maxwell sexually abused them, sexually trafficked them, or that she partook in daily sex with any underage girls. Plaintiff's claim stands in isolation because it is fictional.",
"position": "footer"
},
{
"type": "printed",
"content": "7 This \"circumstantial evidence\" has no bearing on the truthfulness of the stories published by Plaintiff. It is equally likely to show that Plaintiff became aware of the allegations of others and decided to hop on the band wagon. She then made up similar claims for the purpose of getting paid hundreds of thousands of dollars by the media for publicizing her allegations and identifying well know public figures whose names she has seen documents that she reviewed or other stories she had read.",
"position": "footer"
},
{
"type": "printed",
"content": "8",
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],
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"people": [
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"Ghislaine Maxwell",
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"Plaintiff"
],
"organizations": [],
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"05/09/21"
],
"reference_numbers": [
"28589",
"2009 WL 890682",
"DOI-OGR-00004211"
]
},
"additional_notes": "The document appears to be a court filing related to a case involving Ghislaine Maxwell and allegations of sexual abuse. The text is dense and includes legal terminology and references to specific court rules and precedents. There are no visible redactions or damage to the document."
}

67
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@ -0,0 +1,67 @@
{
"document_metadata": {
"page_number": "6",
"document_number": "314",
"date": "07/12/21",
"document_type": "court document",
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"has_stamps": false
},
"full_text": "strong measures to ensure that the balance is never weighed against the accused. The Government's contention that the prosecution won't receive a fair trial based on my statements is completely divorced from the reality of what is occurring in the media in this case. Third, the Government has helped to create a totally unlevel playing field and it should not be heard to complain. For starters, the Government conducted an over-the-top press conference upon Ms. Maxwell's arrest - with blowups, photographs, soundbites, inflammatory language, and strategic pauses to get the most impactful photo opportunity, all designed to stir up the press, inflame the passions of the public, and prejudice the potential jury against Ms. Maxwell. And it worked. The Government's press conference was one of, if not the most, covered Government's press conferences in U.S. history. The Government's complaint about an Op-Ed that discusses the legal impact of the Cosby decision is the definition of chutzpah. Then-U.S. Attorney conducting a press conference on the arrest of Ms. Maxwell with visual aides The Government did not stop with the unjust press conference. It has continued to inflame the press with inappropriate and untruthful statements, thinking that In any event, Rule 23.1(h), which the Government cites as the authority to issue a \"special order\" here, is actually better viewed as concerned with the rights of the accused than the Government. See Rule 23.1(h) (\"The Court, on motion of either party or on its own motion, may issue a special order governing such matters as extrajudicial statements by parties and witnesses likely to interfere with the rights of the accused to a fair trial by an impartial jury....\") (emphasis added). DOJ-OGR-00004960",
"text_blocks": [
{
"type": "printed",
"content": "strong measures to ensure that the balance is never weighed against the accused. The Government's contention that the prosecution won't receive a fair trial based on my statements is completely divorced from the reality of what is occurring in the media in this case.",
"position": "top"
},
{
"type": "printed",
"content": "Third, the Government has helped to create a totally unlevel playing field and it should not be heard to complain. For starters, the Government conducted an over-the-top press conference upon Ms. Maxwell's arrest - with blowups, photographs, soundbites, inflammatory language, and strategic pauses to get the most impactful photo opportunity, all designed to stir up the press, inflame the passions of the public, and prejudice the potential jury against Ms. Maxwell. And it worked. The Government's press conference was one of, if not the most, covered Government's press conferences in U.S. history. The Government's complaint about an Op-Ed that discusses the legal impact of the Cosby decision is the definition of chutzpah.",
"position": "middle"
},
{
"type": "image caption",
"content": "Then-U.S. Attorney conducting a press conference on the arrest of Ms. Maxwell with visual aides",
"position": "middle"
},
{
"type": "printed",
"content": "The Government did not stop with the unjust press conference. It has continued to inflame the press with inappropriate and untruthful statements, thinking that",
"position": "middle"
},
{
"type": "printed",
"content": "In any event, Rule 23.1(h), which the Government cites as the authority to issue a \"special order\" here, is actually better viewed as concerned with the rights of the accused than the Government. See Rule 23.1(h) (\"The Court, on motion of either party or on its own motion, may issue a special order governing such matters as extrajudicial statements by parties and witnesses likely to interfere with the rights of the accused to a fair trial by an impartial jury....\") (emphasis added).",
"position": "bottom"
},
{
"type": "printed",
"content": "DOJ-OGR-00004960",
"position": "footer"
}
],
"entities": {
"people": [
"Maxwell",
"Cosby"
],
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"Court",
"U.S. Attorney",
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],
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"U.S."
],
"dates": [
"07/12/21"
],
"reference_numbers": [
"Case 1:20-cr-00330-PAE",
"Document 314",
"DOJ-OGR-00004960"
]
},
"additional_notes": "The document appears to be a court filing discussing the government's handling of a press conference and its impact on the defendant's right to a fair trial. The text is well-formatted and legible, with a clear structure and headings. There are no visible redactions or damage to the document."
}

59
results/IMAGES002/DOJ-OGR-00005493.json Normal file
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@ -0,0 +1,59 @@
{
"document_metadata": {
"page_number": "38",
"document_number": "382",
"date": "10/29/21",
"document_type": "court document",
"has_handwriting": false,
"has_stamps": false
},
"full_text": "whom the government identified as a victim of his offenses so that they could sue him for damages in civil lawsuits. See NPA at 4 was one of those individuals. The NPA further stipulated that Epstein could not contest his liability in those lawsuits and could not contest the amount of money damages as long as it was agreed upon by the parties. See id sued Epstein under this provision of the NPA and eventually settled with him for Accordingly, the NPA is relevant and admissible, and the defense is entitled to use it to cross-examin about her financial interest. See United States v. Lester, 248 F.2d 329, 334 (2d Cir. 1957) (\"it is permissible to show [on cross-examination] that the witness is financially interested in the outcome of the litigation\"); Crowe v. Bolduc, 334 F.3d 124, 132 (1st Cir. 2003) (evidence that a trial witness has a financial incentive in the outcome of the trial is \"classic evidence of bias, which is routinely permitted on cross-examination\"); United States v. Dees, 34 F.3d 838, 844 (9th Cir. 1994) (the question of whether witness had financial interest in outcome of trial is \"critical\" to the jury's determination of credibility). There is also little risk that the jury will be confused by the introduction of the NPA. The Florida Investigation, which the NPA concluded, will already be a significant part of the government's case-in-chief. It is clear from the government's witness list and exhibit list that it intends to call at least two members of the Palm Beach Police Department, to introduce various items of evidence that were recovered from the search of Epstein's Palm Beach residence in October 2005. These include numerous message pad slips as well as photographs and video of the exterior and interior of the Palm Beach residence. See GX-1-A through GX-1-P; GX-2-A through GX-2-W; GX-3-A through GX-3-KK; GX-4-A through GX-4-K.; GX-201 through GX-296.",
"text_blocks": [
{
"type": "printed",
"content": "whom the government identified as a victim of his offenses so that they could sue him for damages in civil lawsuits. See NPA at 4 was one of those individuals. The NPA further stipulated that Epstein could not contest his liability in those lawsuits and could not contest the amount of money damages as long as it was agreed upon by the parties. See id",
"position": "top"
},
{
"type": "printed",
"content": "sued Epstein under this provision of the NPA and eventually settled with him for Accordingly, the NPA is relevant and admissible, and the defense is entitled to use it to cross-examin about her financial interest. See United States v. Lester, 248 F.2d 329, 334 (2d Cir. 1957) (\"it is permissible to show [on cross-examination] that the witness is financially interested in the outcome of the litigation\"); Crowe v. Bolduc, 334 F.3d 124, 132 (1st Cir. 2003) (evidence that a trial witness has a financial incentive in the outcome of the trial is \"classic evidence of bias, which is routinely permitted on cross-examination\"); United States v. Dees, 34 F.3d 838, 844 (9th Cir. 1994) (the question of whether witness had financial interest in outcome of trial is \"critical\" to the jury's determination of credibility).",
"position": "middle"
},
{
"type": "printed",
"content": "There is also little risk that the jury will be confused by the introduction of the NPA. The Florida Investigation, which the NPA concluded, will already be a significant part of the government's case-in-chief. It is clear from the government's witness list and exhibit list that it intends to call at least two members of the Palm Beach Police Department, to introduce various items of evidence that were recovered from the search of Epstein's Palm Beach residence in October 2005. These include numerous message pad slips as well as photographs and video of the exterior and interior of the Palm Beach residence. See GX-1-A through GX-1-P; GX-2-A through GX-2-W; GX-3-A through GX-3-KK; GX-4-A through GX-4-K.; GX-201 through GX-296.",
"position": "bottom"
}
],
"entities": {
"people": [
"Epstein"
],
"organizations": [
"Palm Beach Police Department"
],
"locations": [
"Palm Beach",
"Florida"
],
"dates": [
"October 2005",
"10/29/21"
],
"reference_numbers": [
"Case 1:20-cr-00330-PAE",
"Document 382",
"GX-1-A",
"GX-1-P",
"GX-2-A",
"GX-2-W",
"GX-3-A",
"GX-3-KK",
"GX-4-A",
"GX-4-K",
"GX-201",
"GX-296"
]
},
"additional_notes": "The document appears to be a court filing related to the case against Epstein. There are several redacted names throughout the text. The document includes references to various court cases and legal precedents."
}

63
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{
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"has_stamps": false
},
"full_text": "Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 53 of 69\ngovernment has provided \"notice\" tha was a \"victim\" in this case, and has disclosed a number of exhibits related to her - school records (GX 781-783); employment records (GX 821-22), photo (GX 332).27 It is apparent that the government hopes to prove that was a \"victim\" in the sense that she was underage when she had sex with Jeffrey Epstein, without calling her as a witness in this case. Again, if the government offers evidence that the sexual contact observed by between and Mr. Epstein amounts to \"sexual abuse\" because was underage, then such testimony would open the door to the mountains of evidence that tends to impeach that assertion.\n\nGiven the failure to specify the statements that will be elicited, the purposes for which those statements qualify as non-hearsay, depriving the defense of an opportunity to brief whether such statements open the door to credibility challenges of the accuser-declarants and , this Court should deny the motion.\n27 Tellingly, the government failed to provide an exhibit for birth certificate, but did for . See GX 11-15.",
"text_blocks": [
{
"type": "printed",
"content": "Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 53 of 69",
"position": "header"
},
{
"type": "printed",
"content": "government has provided \"notice\" tha was a \"victim\" in this case, and has disclosed a number of exhibits related to her - school records (GX 781-783); employment records (GX 821-22), photo (GX 332).27 It is apparent that the government hopes to prove that was a \"victim\" in the sense that she was underage when she had sex with Jeffrey Epstein, without calling her as a witness in this case. Again, if the government offers evidence that the sexual contact observed by between and Mr. Epstein amounts to \"sexual abuse\" because was underage, then such testimony would open the door to the mountains of evidence that tends to impeach that assertion.",
"position": "main body"
},
{
"type": "printed",
"content": "Given the failure to specify the statements that will be elicited, the purposes for which those statements qualify as non-hearsay, depriving the defense of an opportunity to brief whether such statements open the door to credibility challenges of the accuser-declarants and , this Court should deny the motion.",
"position": "main body"
},
{
"type": "printed",
"content": "27 Tellingly, the government failed to provide an exhibit for birth certificate, but did for . See GX 11-15.",
"position": "footer"
},
{
"type": "printed",
"content": "45",
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{
"type": "printed",
"content": "DOJ-OGR-00005508",
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"entities": {
"people": [
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},
"additional_notes": "The document appears to be a court filing related to a case involving Jeffrey Epstein. There are several redacted names and potentially sensitive information throughout the document."
}

53
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@ -0,0 +1,53 @@
{
"document_metadata": {
"page_number": "8",
"document_number": "423",
"date": "11/08/21",
"document_type": "court document",
"has_handwriting": false,
"has_stamps": false
},
"full_text": "Case 1:20-cr-00330-PAE Document 423 Filed 11/08/21 Page 8 of 11\n\nPage 8\n\npresumption of detention, the presumption does not disappear; instead, it becomes a factor to be weighed and considered in deciding whether release is warranted. Id.\n\nWhere the Government seeks detention based on flight risk, the court must consider: (1) \"the nature and circumstances of the offense charged\"; (2) \"the weight of the evidence against the person\"; and (3) the \"history and characteristics of the person.\" 18 U.S.C. § 3142(g).\n\nA detention hearing may be reopened \"at any time before trial if the judicial officer finds that information exists that was not known to the movant at the time of the hearing and that has a material bearing on the issue whether there are conditions of release that will reasonably assure the appearance of such person as required.\" 18 U.S.C. § 3142(f); see also United States v. Bush, No. 18 Cr. 907 (PAC), 2021 WL 371782, at *1 (S.D.N.Y. Feb. 3, 2021) (motion for reconsideration of bail requires defendant to show \"controlling decisions or data that the court overlooked--matters, in other words, that might reasonably be expected to alter the conclusion reached by the court\" (internal citation and quotations omitted)).\n\nC. Discussion\n\nOn three occasions, this Court has correctly found that there are no conditions of release that can reasonably assure the defendant's appearance, given the grave risk of flight that she presents. In three carefully reasoned decisions issued after lengthy briefing and argument, this Court has concluded that detention is appropriate in light of the nature and circumstances of the offense, which carry a presumption of detention; the strength of the Government's proffered evidence; and the defendant's history and characteristics, particularly her substantial international ties, multiple foreign citizenships, familial and personal connections abroad, ownership of at least one foreign property of significant value, lack of candor about her finances, and \"extraordinary capacity to evade detection.\" (First Order at 79-91; Second Order at 7-20; Third Order at 6-11).\n\nDOJ-OGR-00006208",
"text_blocks": [
{
"type": "printed",
"content": "Case 1:20-cr-00330-PAE Document 423 Filed 11/08/21 Page 8 of 11",
"position": "header"
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{
"type": "printed",
"content": "Page 8",
"position": "header"
},
{
"type": "printed",
"content": "presumption of detention, the presumption does not disappear; instead, it becomes a factor to be weighed and considered in deciding whether release is warranted. Id.\n\nWhere the Government seeks detention based on flight risk, the court must consider: (1) \"the nature and circumstances of the offense charged\"; (2) \"the weight of the evidence against the person\"; and (3) the \"history and characteristics of the person.\" 18 U.S.C. § 3142(g).\n\nA detention hearing may be reopened \"at any time before trial if the judicial officer finds that information exists that was not known to the movant at the time of the hearing and that has a material bearing on the issue whether there are conditions of release that will reasonably assure the appearance of such person as required.\" 18 U.S.C. § 3142(f); see also United States v. Bush, No. 18 Cr. 907 (PAC), 2021 WL 371782, at *1 (S.D.N.Y. Feb. 3, 2021) (motion for reconsideration of bail requires defendant to show \"controlling decisions or data that the court overlooked--matters, in other words, that might reasonably be expected to alter the conclusion reached by the court\" (internal citation and quotations omitted)).\n\nC. Discussion\n\nOn three occasions, this Court has correctly found that there are no conditions of release that can reasonably assure the defendant's appearance, given the grave risk of flight that she presents. In three carefully reasoned decisions issued after lengthy briefing and argument, this Court has concluded that detention is appropriate in light of the nature and circumstances of the offense, which carry a presumption of detention; the strength of the Government's proffered evidence; and the defendant's history and characteristics, particularly her substantial international ties, multiple foreign citizenships, familial and personal connections abroad, ownership of at least one foreign property of significant value, lack of candor about her finances, and \"extraordinary capacity to evade detection.\" (First Order at 79-91; Second Order at 7-20; Third Order at 6-11).",
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]
},
"additional_notes": "The document appears to be a court filing related to a criminal case, discussing the detention of a defendant based on flight risk. The text is well-formatted and printed, with no visible handwriting or stamps. The document includes references to specific court codes and previous court decisions."
}

58
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@ -0,0 +1,58 @@
{
"document_metadata": {
"page_number": "23",
"document_number": "424",
"date": "11/08/21",
"document_type": "court document",
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"has_stamps": false
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"full_text": "Case 1:20-cr-00330-PAE Document 424 Filed 11/08/21 Page 23 of 41\ncan be either true or false, and offering an “expert” opinion that allegations can be false is simply prejudicial, not only inviting the jury to speculate about the frequency of false allegations but giving the incorrect impression that they are common. Indeed, if Dr. Dietz seeks to offer such testimony that false accusations “do occur,” it will open the door for the Government to elicit on cross-examination that Dr. Dietz’s principal source, which he relies on “nearly verbatim” (Ex. A at 7), concludes that “the most recent more methodologically adequate studies have indicated that false allegations are somewhat rare” (Ex. C at 101 (citing study estimating the frequency of false rape allegations between 2% and 10%)).6 Of course, the Government’s view is that this entire topic can serve only to distract the jury from its task of determining whether these specific allegations are in fact proven beyond a reasonable doubt, and thus Dr. Dietz should be precluded from offering this opinion.\nMany of the “pathways” Dr. Dietz describes are not just within the ken of the jury, they are at the core of the jury’s role. It is not helpful to the jury or permissible under Rule 702 for an expert to testify that “lying,” a mistake of “implied consent,” or “intoxication” could lead to a false accusation of a crime. Sorting out witness credibility, mistake, or other such circumstances is squarely the function of the jury, which will be instructed by the Court and which does not need the help of a psychiatrist to assess such possibilities. See, e.g., United States v. Mulder, 273 F.3d\n6 The Government typically cannot introduce evidence of the statistical infrequency of false accusations, but if Dr. Dietz is allowed to create a false impression of their frequency, it is only fair to allow the Government to correct the record. United States v. Bilzerian, 926 F.2d 1285, 1296 (2d Cir. 1991) (“The weighing of relevance under Rule 403 may be altered when a false impression is created by earlier testimony. That is, evidence whose probative value might not ordinarily outweigh its prejudicial effect if offered on direct examination is admiss[i]ble to rebut testimony elicited on cross examination that created a false impression.” (citations omitted)).",
"text_blocks": [
{
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"content": "Case 1:20-cr-00330-PAE Document 424 Filed 11/08/21 Page 23 of 41",
"position": "header"
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{
"type": "printed",
"content": "can be either true or false, and offering an “expert” opinion that allegations can be false is simply prejudicial, not only inviting the jury to speculate about the frequency of false allegations but giving the incorrect impression that they are common. Indeed, if Dr. Dietz seeks to offer such testimony that false accusations “do occur,” it will open the door for the Government to elicit on cross-examination that Dr. Dietz’s principal source, which he relies on “nearly verbatim” (Ex. A at 7), concludes that “the most recent more methodologically adequate studies have indicated that false allegations are somewhat rare” (Ex. C at 101 (citing study estimating the frequency of false rape allegations between 2% and 10%)).6 Of course, the Government’s view is that this entire topic can serve only to distract the jury from its task of determining whether these specific allegations are in fact proven beyond a reasonable doubt, and thus Dr. Dietz should be precluded from offering this opinion.",
"position": "main"
},
{
"type": "printed",
"content": "Many of the “pathways” Dr. Dietz describes are not just within the ken of the jury, they are at the core of the jury’s role. It is not helpful to the jury or permissible under Rule 702 for an expert to testify that “lying,” a mistake of “implied consent,” or “intoxication” could lead to a false accusation of a crime. Sorting out witness credibility, mistake, or other such circumstances is squarely the function of the jury, which will be instructed by the Court and which does not need the help of a psychiatrist to assess such possibilities. See, e.g., United States v. Mulder, 273 F.3d",
"position": "main"
},
{
"type": "printed",
"content": "6 The Government typically cannot introduce evidence of the statistical infrequency of false accusations, but if Dr. Dietz is allowed to create a false impression of their frequency, it is only fair to allow the Government to correct the record. United States v. Bilzerian, 926 F.2d 1285, 1296 (2d Cir. 1991) (“The weighing of relevance under Rule 403 may be altered when a false impression is created by earlier testimony. That is, evidence whose probative value might not ordinarily outweigh its prejudicial effect if offered on direct examination is admiss[i]ble to rebut testimony elicited on cross examination that created a false impression.” (citations omitted)).",
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"Document 424",
"Ex. A",
"Ex. C",
"Rule 702",
"Rule 403",
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]
},
"additional_notes": "The document appears to be a court filing related to a criminal case, discussing the admissibility of expert testimony regarding false allegations. The text is well-formatted and free of significant damage or redactions."
}

62
results/IMAGES003/DOJ-OGR-00006389.json Normal file
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@ -0,0 +1,62 @@
{
"document_metadata": {
"page_number": "29 of 54",
"document_number": "438",
"date": "11/12/21",
"document_type": "Court Document",
"has_handwriting": false,
"has_stamps": false
},
"full_text": "Case 1:20-cr-00330-PAE Document 438 Filed 11/12/21 Page 29 of 54\n\nDep't of Justice, Office of Professional Responsibility Report, Dkt. No 293 Ex. A). Discussion of those issues would be all the more confusing to the jury because it involves decisions of a different prosecuting authority, because the USAO-SDFL resolved its investigation before significant investigative steps were completed, and because the USAO-SDFL investigation did nonetheless generate inculpatory material as to the defendant. To evaluate the evidence, jurors would also need to understand the sequencing of the various investigations into Epstein and the defendant, so they could understand which witnesses and evidence were available to which law enforcement agencies and prosecutors at what times. The history of various investigations into Epstein reaches back 20 years, and a review of that history would create an extensive sideshow. Any marginal probative value of evidence of the Government's charging decisions is substantially outweighed by the extended digression and confusion that such evidence would require.\n\nThird, eliciting information about past charging decisions would be hearsay. See White, 692 F.3d at 244-45 (declining to decide whether the evidence in that case was hearsay); id. at 253 (Jacobs, J., dissenting) (\"[A]s the majority opinion observes, hearsay problems abound in this case; yet, since neither party raised these issues on appeal, the Court has not decided whether the charging documents . . . are admissible hearsay.\"). Those charging decisions were made internally by prosecutors at the USAO-SDFL or at this Office. No prosecutors from either office are testifying at trial, and no witness testifying at this trial can explain the Government's past charging decisions. Any knowledge that an FBI agent has, or that a witness has, about the basis for a prior charging decision is based on statements made by prosecutors, which are themselves hearsay.\n\n28\n\nDOJ-OGR-00006389",
"text_blocks": [
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"content": "Case 1:20-cr-00330-PAE Document 438 Filed 11/12/21 Page 29 of 54",
"position": "header"
},
{
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"content": "Dep't of Justice, Office of Professional Responsibility Report, Dkt. No 293 Ex. A). Discussion of those issues would be all the more confusing to the jury because it involves decisions of a different prosecuting authority, because the USAO-SDFL resolved its investigation before significant investigative steps were completed, and because the USAO-SDFL investigation did nonetheless generate inculpatory material as to the defendant. To evaluate the evidence, jurors would also need to understand the sequencing of the various investigations into Epstein and the defendant, so they could understand which witnesses and evidence were available to which law enforcement agencies and prosecutors at what times. The history of various investigations into Epstein reaches back 20 years, and a review of that history would create an extensive sideshow. Any marginal probative value of evidence of the Government's charging decisions is substantially outweighed by the extended digression and confusion that such evidence would require.",
"position": "main"
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{
"type": "printed",
"content": "Third, eliciting information about past charging decisions would be hearsay. See White, 692 F.3d at 244-45 (declining to decide whether the evidence in that case was hearsay); id. at 253 (Jacobs, J., dissenting) (\"[A]s the majority opinion observes, hearsay problems abound in this case; yet, since neither party raised these issues on appeal, the Court has not decided whether the charging documents . . . are admissible hearsay.\"). Those charging decisions were made internally by prosecutors at the USAO-SDFL or at this Office. No prosecutors from either office are testifying at trial, and no witness testifying at this trial can explain the Government's past charging decisions. Any knowledge that an FBI agent has, or that a witness has, about the basis for a prior charging decision is based on statements made by prosecutors, which are themselves hearsay.",
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},
"additional_notes": "The document appears to be a court filing related to a criminal case involving Epstein. The text discusses the potential confusion and hearsay issues related to introducing evidence of past charging decisions. The document is well-formatted and free of significant damage or redactions."
}

73
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{
"document_metadata": {
"page_number": "14",
"document_number": "444",
"date": "11/12/21",
"document_type": "court document",
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},
"full_text": "Case 1:20-cr-00330-PAE Document 444 Filed 11/12/21 Page 14 of 21 allegations in the indictment does not somehow convert this evidence into proof of the charged conspiracies. Such a rule would allow the government to entirely circumvent Rule 404(b) simply by charging other act conduct in the indictment. Moreover, without a proper limiting instruction, there is a serious risk that the jury will view this lawful conduct as evidence of criminal propensity. See United States v. Dolney, No. 04-CR-159 (NGG), 2005 WL 2129169, at *2 (E.D.N.Y. Sept. 1, 2005) (benefit of applying Rule 404(b) is \"the value that a limiting instruction will have in ensuring that the jury does not view the defendants' alleged prior conduct as evidence of the defendants' propensity to engage in criminal activity\"). At the very least, it is not \"manifestly clear\" that the evidence related to Accuser-3 is proof of the charged Mann Act conspiracies. Accordingly, \"the proper course is to proceed under Rule 404(b).\" Townsend, 2007 WL 1288597, at *1 (citing Nektalov, 325 F. Supp. 2d at 372). III. Evidence Related to Accuser-3 Is Not Admissible Under Rule 404(b) and Should be Excluded Under Rule 403 The Court should also not admit evidence related to Accuser-3 as Rule 404(b) evidence because it will be offered solely to show Ms. Maxwell's criminal propensity and will be unfairly",
"text_blocks": [
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"content": "Case 1:20-cr-00330-PAE Document 444 Filed 11/12/21 Page 14 of 21",
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},
{
"type": "printed",
"content": "allegations in the indictment does not somehow convert this evidence into proof of the charged conspiracies. Such a rule would allow the government to entirely circumvent Rule 404(b) simply by charging other act conduct in the indictment.",
"position": "top"
},
{
"type": "printed",
"content": "Moreover, without a proper limiting instruction, there is a serious risk that the jury will view this lawful conduct as evidence of criminal propensity. See United States v. Dolney, No. 04-CR-159 (NGG), 2005 WL 2129169, at *2 (E.D.N.Y. Sept. 1, 2005) (benefit of applying Rule 404(b) is \"the value that a limiting instruction will have in ensuring that the jury does not view the defendants' alleged prior conduct as evidence of the defendants' propensity to engage in criminal activity\"). At the very least, it is not \"manifestly clear\" that the evidence related to Accuser-3 is proof of the charged Mann Act conspiracies. Accordingly, \"the proper course is to proceed under Rule 404(b).\" Townsend, 2007 WL 1288597, at *1 (citing Nektalov, 325 F. Supp. 2d at 372).",
"position": "middle"
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{
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"content": "III. Evidence Related to Accuser-3 Is Not Admissible Under Rule 404(b) and Should be Excluded Under Rule 403",
"position": "middle"
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{
"type": "printed",
"content": "The Court should also not admit evidence related to Accuser-3 as Rule 404(b) evidence because it will be offered solely to show Ms. Maxwell's criminal propensity and will be unfairly",
"position": "bottom"
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{
"type": "printed",
"content": "10",
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]
},
"additional_notes": "The document appears to be a court filing with redactions. The text is mostly legible, but some parts are blacked out."
}

76
results/IMAGES003/DOJ-OGR-00006845.json Normal file
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{
"document_metadata": {
"page_number": "10 of 45",
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},
"full_text": "Case 1:20-cr-00330-PAE Document 452-2 Filed 11/12/21 Page 10 of 45 Table 1. (continued) Study | Purpose | Design | Sample | Findings | Summary Priebe and Svedin (2008) | This study aimed to investigate disclosure rates and predictors of disclosure and nondisclosure | Participants completed a 65-item questionnaire that included questions about background, consensual sex, sexual abuse experiences, and disclosure | The sample consisted of 4,339 high school students in Sweden (2,322 boys) | The mean age of participants was 18.15 years. This study used CSA and noncontact abuse (contact abuse or penetration). 1,962 participants reported CSA and answered questions about disclosure | Fewer had reported to a professional (contact abuse or penetration) for girls, but overall rates for girls were higher than for boys. The more severe the sexual abuse, the more likely girls were to disclose to a professional. Boys were less likely to disclose to a professional, but more likely to disclose to a peer. Key to disclosure was having a supportive mother or father. Boys were more likely to disclose to a peer. Study focused on male survivors of CSA disclosure challenges: (1) To understand three issues: (1) To understand disclosure rates and predictors of disclosure and nondisclosure | Male survivors of CSA were interviewed about their disclosure experiences. Analyses included 16 male survivors of CSA | 268 DOJ-OGR-00006845",
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"content": "Table 1. (continued)",
"position": "top"
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"position": "top"
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{
"type": "printed",
"content": "Priebe and Svedin (2008) | This study aimed to investigate disclosure rates and predictors of disclosure and nondisclosure | Participants completed a 65-item questionnaire that included questions about background, consensual sex, sexual abuse experiences, and disclosure | The sample consisted of 4,339 high school students in Sweden (2,322 boys) | The mean age of participants was 18.15 years. This study used CSA and noncontact abuse (contact abuse or penetration). 1,962 participants reported CSA and answered questions about disclosure | Fewer had reported to a professional (contact abuse or penetration) for girls, but overall rates for girls were higher than for boys. The more severe the sexual abuse, the more likely girls were to disclose to a professional. Boys were less likely to disclose to a professional, but more likely to disclose to a peer. Key to disclosure was having a supportive mother or father. Boys were more likely to disclose to a peer.",
"position": "middle"
},
{
"type": "printed",
"content": "Sorenson, Keating, and Grosman (2008)",
"position": "middle"
},
{
"type": "printed",
"content": "Study focused on male survivors of CSA disclosure challenges: (1) To understand three issues: (1) To understand disclosure rates and predictors of disclosure and nondisclosure | Male survivors of CSA were interviewed about their disclosure experiences. Analyses included 16 male survivors of CSA",
"position": "middle"
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{
"type": "printed",
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}
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},
"additional_notes": "The document appears to be a court document related to a case involving child sexual abuse. The page contains a table summarizing various studies on the topic. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and easy to read."
}

74
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{
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"full_text": "Case 1:20-cr-00330-PAE Document 452-2 Filed 11/12/21 Page 16 of 45 (continued) Table I. (continued) Study Kogan (2004) Goodman-Brown, Edelstein, Jones and Gordon (2003) Purpose The purpose of this study was to identify factors that influence the disclosure made by female survivors of childhood sexual abuse and to assess the nature of both the disclosure and the receipt of the disclosure. The purpose of this study was to investigate variables associated with child sexual abuse disclosure. Case file reviews of data obtained from prosecutors' offices were conducted for CSA and prosecution on files, as well as structured interviews with the children's caretaker. Incident Categorization modified CSA categorization questions about each sexual event including unwanted sexual contact, character stats and perpetrator character stats were investigated. A subsample of 263 adolescent females between 12 and 17 years old, mean age of 15.7 years old, who reported at least one experience of sexual contact in the NSA, were assessed using a modified CSA categorization. Interviewers asked a series of questions about each unwanted sexual event including unwanted sexual contact, character stats and perpetrator character stats. Data were gathered from a subsample of female adolescents who participated in the NSA. Sample Participants were 218 children referred to CSA, a program for children who had allegedly been sexually abused CSA, a program for children who had allegedly been sexually abused. A total of 64% disclosed within a month and 29% disclosed within 6 months. Five variables were tested: (1) age of child disclosure mode, (2) type of victim consequences of abuse, (3) fear of negative consequences of disclosure. Findings Significant predictors of delay were younger age at first event and evidence of the 26 women who did not disclose during the period with ongoing abuse, 15 worried about not being believed after disclosure. Children under the age of 7 were at risk for delayed disclosure. CSA participants whose USE occurred between the ages of 7 and 13 were more likely to tell an adult. Adolescent peers were more likely to be told than children aged 7-10 years. Children beyond 11-13 tended to disclose to a family member or a friend. Immediate disclosure was associated with a stranger perpetrator. Fear of negative consequences was minimized when the perpetrator was a family member. Legal sample (32%) may account for earlier disclosures. Account suggests that older children with higher rates of extrafamilial abuse compared to intrafamilial abuse, felt greater negative consequences of disclosure, and so the time lag between the USE and disclosure was presumably shorter than study of adult CSA participants. Summary This study examined factors related to disclosure of USEs that occurred in childhood and adolescence. Although data may be retrospective, recall bias may have minimized the results since participants were asked to disclose USE via survey. A though ado escents were associated with a household member, (2) they made surveys more prompt, and (3) they were more likely to tell an adult. This study represents a higher rate of disclosure than in a reported author on which they may expand mode. These cases had been reported to prosecutors and were in process of prosecution. Legal sample with higher rate of extrafamilial abuse (52%) may account for earlier disclosures. Account suggests that older children with higher rates of extrafamilial abuse compared to intrafamilial abuse, felt greater negative consequences of disclosure, and so the time lag between the USE and disclosure was presumably shorter than study of adult CSA participants. Design Data were gathered from a subsample of female adolescents who participated in the NSA. Data were gathered from a subsample of female adolescents who participated in the NSA. 274",
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"full_text": "Case 1:20-cr-00330-PAE Document 467 Filed 11/15/21 Page 148 of 158 148 LBAAMAX5ps Rocchio - Cross 1 Q. All right. And if we go to the summary here, the author is critical of offender-generated data or questions \"offender-generated data through self-reports because it could be subject to cognitive distortions -- minimization or exaggerations,\" correct? 6 A. I think that they are identifying potential issues that could be present with offender-generated data. 8 Q. Right. If we go to page 4, the McElvany and Culhane article. 10 A. The opinions in that study did continue. You didn't refer to all of their opinions, just part of them. 12 Q. That's OK. The government can ask you questions on redirect if they'd like. 14 A. OK. 15 Q. In this opinion, in this, the findings are, \"Majority of children told their mothers and their peers first.\" Do you see that? 18 A. Of those who disclosed, the majority told mothers and peers, yes. 20 Q. Right. Then the next study, 2014, when the -- 21 A. So that study, though, was among -- everybody in that study had already disclosed. It was a study of children who had already disclosed, to look at who they disclosed to. 24 Q. Right. 25 Then we have the next study here, \"220 minor victims\" SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007327",
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"content": "1 Q. All right. And if we go to the summary here, the author is critical of offender-generated data or questions \"offender-generated data through self-reports because it could be subject to cognitive distortions -- minimization or exaggerations,\" correct? 6 A. I think that they are identifying potential issues that could be present with offender-generated data. 8 Q. Right. If we go to page 4, the McElvany and Culhane article. 10 A. The opinions in that study did continue. You didn't refer to all of their opinions, just part of them. 12 Q. That's OK. The government can ask you questions on redirect if they'd like. 14 A. OK. 15 Q. In this opinion, in this, the findings are, \"Majority of children told their mothers and their peers first.\" Do you see that? 18 A. Of those who disclosed, the majority told mothers and peers, yes. 20 Q. Right. Then the next study, 2014, when the -- 21 A. So that study, though, was among -- everybody in that study had already disclosed. It was a study of children who had already disclosed, to look at who they disclosed to. 24 Q. Right. 25 Then we have the next study here, \"220 minor victims\"",
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"full_text": "identification.\" Id. (internal quotation marks omitted); see Fed. R. Evid. 901(a). The \"standard for authentication is one of 'reasonable likelihood' and is 'minimal.' The testimony of a witness with knowledge that a matter is what it is claimed to be is sufficient to satisfy this standard.\" United States v. Gagliardi, 506 F.3d 140, 151 (2d Cir. 2007) (citations and internal quotation marks omitted). After this low bar is satisfied, \"the other party then remains free to challenge the reliability of the evidence, to minimize its importance, or to argue alternative interpretations of its meaning, but these and similar other challenges to go the weight of the evidence—not to its admissibility.\" United States v. Tan Yat Chin, 371 F.3d 31, 38 (2d Cir. 2004) (emphases in original).\n\nThe defendant's argument suggests that Government Exhibit 52 is unique in a way unsupported by the evidence. Government Exhibit 52 is a bound, sewn, typed address book with a particular cover. Employee-1 will testify that, based on its appearance, contents, and distinctive characteristics, it appears to be a copy of the defendant's address book. She will also testify that other bound, sewn, typed copies of the same address book with the same cover were located in specific places in Epstein's Palm Beach house, as was the operating practice of Epstein's house. That testimony is corroborated by Government Exhibit 606, the household manual, which states that \"A copy of Mr Epstein and Ms Maxwell's telephone directories must be placed to the right of each telephone (except for the Guestrooms).\" (GX 606 at 7). And it is corroborated by Mr. Rodriguez himself, whose counsel said at sentencing in his case that the book he possessed was \"a copy of the book, of which there were many copies, and Mr. Rodriguez had one as Mr. Epstein's house man.\" Sent. Tr. at 10, United States v. Rodriguez, 10 Cr. 80015 (KAM) (S.D.F.L. June 18,",
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"full_text": "Case 1:20-cr-00330-PAE Document 491 Filed 11/22/21 Page 4 of 6 defendant at the time. See United States v. Prevezon Holdings, Ltd., 319 F.R.D. 459, 463 (S.D.N.Y. 2017) (describing \"distinctive characteristics\" for purposes of Fed. R. Evid. 901(b)(4) to include \"pages of 'nonpublic information'\"). The Court can readily reject the defendant's suggestion that Government Exhibit 52 is a forgery. The book is sewn, bound, and contains an extensive set of private information. The defense offers no theory for how Mr. Rodriguez could have generated that information and bound it together seamlessly in an address book that could fool Employee-1. Further, if the address book were a forgery, it would have provided Mr. Rodriguez with a complete defense in his criminal case: the defendant could not have impaired a grand jury investigation by \"concealing\" a forged document. See 18 U.S.C. § 1512(c). Instead, Mr. Rodriguez was sentenced to eighteen months in prison. Nor is there reason to believe that the book was altered in any significant way by Mr. Rodriguez. As the Court can see from the pages the Government has marked separately (see GX 52-A through G2-H), any handwriting is minimal and non-substantive, at least on the pages the Government intends to emphasize at trial. The \"added tabs\" the defendant mentions are literally sticky notes attached to certain pages, likely added by law enforcement after they seized the book from Mr. Rodriguez. And the \"additional handwritten pages\" to which the defendant refers are Mr. Rodriguez's separate notes that are not part of Government Exhibit 52. See Plea Agreement/Factual Proffer Statement ¶ 10(f), Rodriguez, 10 Cr. 80015 (KAM), Dkt. No. 25 DOJ-OGR-00007415",
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"full_text": "Case 1:20-cr-00330-PAE Document 499-1 Filed 11/23/21 Page 46 of 375\nmemories of event details. Psychological Science. 25, 1674-1681.\nStrange, D. , Dysart, J., & Loftus, E.F. (2014) Why alibi errors are not necessarily evidence of guilt. Zeitschrift fur Psychologie. (Special issue on Applied Memory Research), 222, 82-89.\nTurgeon, J., Francis, E., & Loftus, E. (2014, Sept-Oct) Crafting model jury instructions for evaluating eyewitness testimony. The Pennsylvania Lawyer, Vol 36, p 49-52.\nMichael, R.B., Braniff, G., Garry, M. & Loftus, E.F. (2014) Thinking about regret: Number of memories and ease of retrieval influence judgments about regret. Psychology of Consciousness: Theory, Research & Practice, 1, 329-338..\nPatihis, L., Lilienfeld, S.O., Ho, L.Y. & Loftus, E.F. (2014) Unconscious repressed memory is scientifically questionable. Psychological Science, 25, 1967-68 (Commentary)\nWylie, L. E., Patihis, L., McCuller, L. L., Davis, D., Brank, E. M., Loftus, E. F., & Bornstein, B. H. (2014). Misinformation effects in older versus younger adults: A meta-analysis and review. In M. P. Toglia, D. F. Ross, J. Pozzulo, & E. Pica (Eds) The Elderly Eyewitness in Court, UK: Taylor & Francis., p 38 -66.\nLoftus, E.F. (2014, Feb. 14) Unknown: What happened in the attic; Known: memory is malleable. National Law Journal. (opinion)\nGrady, R.H. & Loftus, E.F. (2014, Dec. 24) (Mis)remembering sexual assault. Daily Journal (op-ed)\nLoftus, E. F. (2014) Illusions of Memory. In Crangle, C.E., de la Sierra, A.G., & Longino, H.E. (Eds). Foundations and methods from mathematics to neuroscience: Essays inspired by Patrick Suppes. CSLI Publications., Stanford, Calif. (Center for the Study of Language and Information). p 225-229.\nPatihis, L., Davis, D., & Loftus, E.F. (2014) Memory. In T.R. Levine (Ed.) Encyclopedia of Deception. Thousand Oaks, Ca: Sage, p 656-658.\nPatihis, L., Davis, D., & Loftus, E.F. (2014) Repressed memories. In T.R. Levine (Ed.) Encyclopedia of Deception. Thousand Oaks, Ca: Sage, p. 814-817.\nNewman, E. J., Frenda, S. J., & Loftus, E. F. (2014). False Memories. In Encyclopedia of Criminology and Criminal Justice (pp. 1555-1563). NY: Springer\n2015\nLoftus, E.F. (2015) Crimes of memory: False Memories and Societal Justice, In M.A. Gernsbacher & J.R. Pomerantz (Eds) Psychology and the Real World. 2nd Ed. NY: Worth, p 87-93.\nNichols, R. M., Bogart, D., and Loftus, E. F. (2015). False Memories. In International Encyclopedia of Social and Behavioral Sciences 2nd Ed. (Vol 8, pp 709-714) Oxford, UK: Elsevier. DOI: 10.1016/B978-0-08-097086-8.51034-4\nBerkowitz, S.R., Enright, K., Bowman-Fowler, N., & Loftus, E.F. (2015) Eyewitness Testimony. In A. Jamieson & A.A. Moenssens (Eds) Encyclopedia of Forensic Science. John Wiley: Chichester. DOI: 10..1002/9780470061589.fsa264.pub2\nLoftus, E.F., Doyle, J.M., & Dysart, J.E. (2015) Eyewitness testimony: Civil & Criminal. 5th Ed. 2015 Cumulative Supplement, p 1-22. Charlottesville, VA: Lexis Law Publishing,\nDavis, D. & Loftus, E.F. (2015) Repressed Memories. In R.L. Cautin & S.O. Lilienfeld (Eds) The Encyclopedia of Clinical Psychology. P 1-3 NY: Wiley DOI:10.1002/9781118625392.wbecp270\nCochran, K.J., Bogart, D.F., Peterson, T, & Loftus, E.F. (2015) Memory: Reconstructive. Wiley Encyclopedia of Forensic Science, p 1-5 DOI: 10.1002/9780470061589.fsa607.pub2.\nBogart, D.F. & Loftus,E.F. (2015) Memory: Repressed. Wiley Encyclopedia of Forensic Science, p 1-7. DOI: 10.1002/9780470061589.fsa283.pub2\n2016\nPatihis, L. & Loftus, E.F. (2016) Crashing Memory 2.0: False memories in adults for an upsetting childhood event. Applied Cognitive Psychology 30, 41-50. DOI: 10.1002/acp.3165\nTakarangi, M. K. & Loftus, E.F. (2016) Suggestion, placebos and false memories. In A. Raz & C.S. Harris (Eds) Placebos Talks: Modern perspectives on placebos in society. Oxford Univ Press. p 204-226.\n31",
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"full_text": "Case 1:20-cr-00330-PAE Document 499-2 Filed 11/23/21 Page 48 of 15947 LBAGmax2 Rocchio - Direct trauma bonding is typically referring to a relationship of attachment and connection between the pimp and the sex worker. We know that the majority of sex workers are under some third-party control. And we know that the trauma bonding is often the means by which the pimp has coerced the sex worker to get them to do their bidding, similar to the kinds of techniques that traffickers might use. So there's a significant amount of overlap. And there has been actually some recent research -- this is one example -- but others have specifically looked at grooming as it applies to trafficking, for example. THE COURT: Thank you. BY MS. POMERANTZ: Q. Dr. Rocchio -- withdrawn. MS. POMERANTZ: Can we pull up Government Exhibit 3, please. BY MS. POMERANTZ: Q. Dr. Rocchio, do you recognize this? A. I do. Q. What is it? A. It's an article validating a model of child sexual abusers. Q. Who wrote this? A. Georgia Winters, Elizabeth Jeglic and Leah Kaylor. MS. POMERANTZ: The government offers Government Exhibit 3. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007916",
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"full_text": "Case 1:20-cr-00330-PAE Document 499-2 Filed 11/23/21 Page 60 of 15959 LBAGmax2 Rocchio - Direct\n1 Q. I wanted to direct your attention to the use of the term grooming, so in that top paragraph. If you could review the section of the article that starts with \"If their use of the term grooming\" and all the way to the end of that paragraph and let me know when you have had a chance to review it, please.\n2 A. Okay.\n3 Q. Dr. Rocchio, what is your response, reaction to this passage?\n4 A. It's a bit confusing as to the point that's being made. I feel like they're trying to -- the author here seems to be mixing different applications of the term that they use grooming, so it looks like in part he's talking about what is true in the literature, which is that we're not particularly good as a field of taking, frankly, many behaviors at all and predicting future behaviors. So he's saying accurately that we can't look at specific behaviors alone as predictors.\n5 And certainly, the use of the term grooming, again, is used to describe a process, a pattern of behaviors. I'm not here today to say that if somebody engages in any one of these particular behaviors, yes, we know you're a child abuser. So he's making that point. But I don't think anybody -- I don't think that -- if that's his point, I wouldn't disagree with that. Except that he's then going on -- I disagree where he says that grooming then can't involve behaviors that might in fact be prosocial or normal.\n6 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00007928",
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"full_text": "Case 1:20-cr-00330-PAE Document 529 Filed 12/08/21 Page 8 of 18 8\nwell take that up at sidebar in a moment. And as I said, only if the jurors indicated a specific wish to speak not in public because the answer would embarrass them or otherwise seriously compromise their privacy, other than that, we'll proceed in open court. But with respect to those, I'm doing that to ensure juror candor and honesty and ultimately ensure the selection of a fair and impartial jury.\nProcess-wise, during the questioning, as the juror is answering my questions in the voir dire, if I think a juror answers in a way that would require striking for cause, I'll ask counsel whether they have any objection. Meaning do you have any objection to me striking for cause. Assuming no objection, then I will strike that juror for cause, and they'll be excused and we'll give them instructions.\nIf I don't think that any answer requires a striking for cause before we get to the individual questions at the end of the voir dire, I'll ask counsel if they have specific followup. If you have specific followup, I'll hear you at sidebar, that is, outside the hearing of the juror, consider your request for followup, and then either engage in that followup or not, and proceed apace.\nIf we have a juror for whom there is no basis to strike for cause, at that point, we'll proceed to have them respond to the individual questions in the voir dire. And then they won't be struck, so they'll be given instructions on\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00008252",
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100
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"full_text": "Case 1:20-cr-00330-PAE Document 582 Filed 01/25/22 Page 1 of 4\nDavis Wright Tremaine LLP\nSuite 500 East\n1301 K Street NW\nWashington, D.C. 20005-3317\nNathan Siegel\n202.973.4237 tel\nNathanSiegel@dwt.com\nJanuary 25, 2022\nVIA ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\n40 Foley Square, Room 2102\nNew York, NY 10007\nRe: USA v. Maxwell, No. 1:20-cr-00330-AJN\nDear Judge Nathan,\nI write on behalf of American Broadcasting Companies, Inc. (\"ABC News\") and NBCUniversal News Group (\"NBC News\") to join in the requests of The Miami Herald (Dkt. No. 581) and The New York Times to oppose the sealing of the motion for a new trial and supporting exhibits filed by the Defendant (Dkt. No. 578), for all the reasons set forth in those requests.\nABC News and NBC News further respectfully request that Juror 50's motion to intervene, which according to this Court's prior orders (Dkt. Nos. 575 & 576) was e-mailed to the Court and placed under temporary seal, now be unsealed. Like the Defendant's Motion for a New Trial, Juror 50's motion is a \"judicial document\" to which the presumption of access under both the common law and the First Amendment applies because Juror 50's motion has been, and continues to be, highly \"relevant to the performance of the judicial function and useful in the judicial process.\" U.S. v. Amadeo, 44 F. 3d 141, 145 (2d Cir. 1995) (\"Amodeo I\").\nDWT.COM\nAnchorage | Bellevue | Los Angeles | New York\nPortland | San Francisco | Seattle | Washington, D.C.\n4863-7911-5787v.1 0019918-000033\nDOJ-OGR-00008829",
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"content": "I write on behalf of American Broadcasting Companies, Inc. (\"ABC News\") and NBCUniversal News Group (\"NBC News\") to join in the requests of The Miami Herald (Dkt. No. 581) and The New York Times to oppose the sealing of the motion for a new trial and supporting exhibits filed by the Defendant (Dkt. No. 578), for all the reasons set forth in those requests.",
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"content": "ABC News and NBC News further respectfully request that Juror 50's motion to intervene, which according to this Court's prior orders (Dkt. Nos. 575 & 576) was e-mailed to the Court and placed under temporary seal, now be unsealed. Like the Defendant's Motion for a New Trial, Juror 50's motion is a \"judicial document\" to which the presumption of access under both the common law and the First Amendment applies because Juror 50's motion has been, and continues to be, highly \"relevant to the performance of the judicial function and useful in the judicial process.\" U.S. v. Amadeo, 44 F. 3d 141, 145 (2d Cir. 1995) (\"Amodeo I\").",
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"full_text": "The Honorable Alison J. Nathan\nFebruary 1, 2022\nPage 4\n\nTo determine whether sealing a document is appropriate, the Court must engage in a multi-step process. First, the Court must determine whether the document is a \"judicial document\" to which a presumption of access would attach. Silver, 2016 WL 1572993, at *3 (citing Newsday LLC v. Cty. of Nassau, 730 F.3d 156, 166, 167 n.15 (2d Cir. 2013)). If it is a \"judicial document,\" the Court must next determine whether the common law right of access or the \"more robust\" First Amendment right of access applies. Id. (citing Lugosch, 435 F.3d at 120). If the document is subject to the common law right of access, the Court must \"determine the weight of the presumption and measure it against competing considerations.\" Id. (citing United States v. Erie Cty. N.Y., 763 F.3d 235, 241 (2d Cir. 2014)); accord Lugosch, 435 F.3d at 119-20. If the document is subject to the more stringent First Amendment right of access, the Court must determine \"by specific, on the-record-findings whether higher values necessitate a narrowly tailored sealing.\" Id. (cleaned up); accord Lugosch, 435 F.3d at 124. In either case, the Court must also determine whether redaction is \"a viable remedy,\" or whether the document presents \"an all or nothing matter.\" Id. (quoting Amodeo II, 71 F.3d at 1053).\n\nDiscussion\n\nMs. Maxwell does not dispute that the Motion is a \"judicial document\" that is subject to a strong presumption of access under both the First Amendment and the common law. See United States v. Smith, 985 F. Supp. 2d 506, 517 (S.D.N.Y. 2013) (citing United States v. Gerena, 869 F.2d 82, 85 (2d Cir. 1989) (right of access under the First Amendment extends to briefs and memoranda filed in connection with post-trial motions in criminal cases)); id. at 518 (presumption\n\n2087306.1\n\nDOJ-OGR-00008903",
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"content": "To determine whether sealing a document is appropriate, the Court must engage in a multi-step process. First, the Court must determine whether the document is a \"judicial document\" to which a presumption of access would attach. Silver, 2016 WL 1572993, at *3 (citing Newsday LLC v. Cty. of Nassau, 730 F.3d 156, 166, 167 n.15 (2d Cir. 2013)). If it is a \"judicial document,\" the Court must next determine whether the common law right of access or the \"more robust\" First Amendment right of access applies. Id. (citing Lugosch, 435 F.3d at 120). If the document is subject to the common law right of access, the Court must \"determine the weight of the presumption and measure it against competing considerations.\" Id. (citing United States v. Erie Cty. N.Y., 763 F.3d 235, 241 (2d Cir. 2014)); accord Lugosch, 435 F.3d at 119-20. If the document is subject to the more stringent First Amendment right of access, the Court must determine \"by specific, on the-record-findings whether higher values necessitate a narrowly tailored sealing.\" Id. (cleaned up); accord Lugosch, 435 F.3d at 124. In either case, the Court must also determine whether redaction is \"a viable remedy,\" or whether the document presents \"an all or nothing matter.\" Id. (quoting Amodeo II, 71 F.3d at 1053).",
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"full_text": "Case 1:20-cr-00336-PAE Document 616-2 Filed 08/24/22 Page 20 of 130 A-5705 C2GFDAU1 Brune - direct 248 1 Q. Do I understand correctly that she generally was not involved in the litigation of this matter on trial? 2 A. She helps out. She helped me certainly with the closing statement, but you're right, she was not on the trial team. 3 Q. She generally did not appear at court appearances, though, is that correct? 4 A. That's correct. 5 Q. And you've had many trials, both in your government experience and your experience as private counsel, correct? 6 A. You know, I've had three trials as a defense lawyer. So I don't know if that would qualify as many. But I certainly have handled quite a few between work in the government and work on the defense. 7 Q. And I take it that when you were an assistant you also conducted many Grand Jury investigations, correct? 8 A. Many. 9 Q. And you know that an important part of any Grand Jury investigation are the details, correct? 10 A. That's certainly so. 11 Q. And you know how to pay attention to details, is that correct? 12 A. I try very hard to pay attention to detail. 13 Q. And I take it that you would agree that you were vested in the success of you law firm, correct? 14 A. I am very vested, very proud of it. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009309",
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"full_text": "Case 1:20-cv-03308-PAE Document 61602 Filed 02/24/22 Page 119 of 130 A-5804 CZGFDAU3 Edelstein 347 1 A. Simply because there are two different addresses. 2 Q. Now, could I ask you to look at page 32, footnote 13. And 3 specifically the last sentence of that footnote. Do you see 4 where it says, \"Defendants had no basis to inquire whether 5 Conrad was lying in response to each of the Court's, 6 questions,\" do you see that? 7 A. Yes. 8 Q. Do you think that was an accurate statement, Ms. Edelstein? 9 A. Yes. 10 Q. Were you aware that Theresa Trzaskoma had been, had 11 discovered the Appellate Division suspension report at that 12 time with the name Catherine Conrad? 13 A. I was aware that Theresa, when we were writing the brief I 14 was aware that Theresa had known that there was an Appellate 15 Division order. 16 Q. And would you turn to page 9 and look at the first full 17 paragraph there. Would you read that first sentence aloud for 18 us? 19 A. \"The tone and content of the letter, which were in sharp 20 contrast to the image Conrad had projected through the trial, 21 always head down, taking notes, caused defendants concern and 22 prompted them to investigate.\" 23 Q. Well, you were aware when that sentence went into the final 24 version of the brief, that Theresa Trzaskoma had already done a 25 bit of investigation, correct? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009408",
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"full_text": "Case 1:20-cr-00336-PAE Document 616 Filed 08/24/22 Page 83 of 117\nA-5926\n\nCAC3PARC 24\n1 Mr. Shechtman, do you want to be heard further?\n2 MR. SHECHTMAN: I will and I will try to be brief,\n3 Judge. I think really four points. The government has\n4 repeated at the argument here what it said in its brief. Which\n5 was that Mr. Parse benefited from the strategic choice that his\n6 clients made and I'll hold the strategic choice point for\n7 second. But I take that to mean that he got acquitted here\n8 because she was on the jury. And that, my father used to say\n9 arguments were nonsense on stilts, and that is nonsense on\n10 stilts. I mean, your Honor knows exactly what happened here.\n11 There was a partisan in the jury room, a woman who couldn't\n12 follow instructions and the like. Your opinion couldn't be\n13 stronger on the point. And she was fighting the good fight to\n14 convict him on 100 percent.\n15 So to say we got the benefit of having her on there\n16 because we were acquitted isn't worthy, respectfully, of the\n17 government.\n18 And the related point this was a split verdict, it is\n19 a split verdict because she couldn't carry the ball as far as\n20 she wanted to, but not because Mr. Parse benefited by her\n21 presence.\n22 The second thing I'd say is this. I take it there are\n23 two competing visions of what happened here, and at the end of\n24 the day, your Honor is going to have to decide. One is that\n25 what happened in that court, your Honor, in the plaza, is that\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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"full_text": "Case 1:20-cr-00338-PAE Document 1616620 Filed 02/24/22 Page 95 of 117 A-5938 Case 1:09-cr-00581-WHP Document 604 Filed 03/16/13 Page 9 of 14 ZUCKERMAN SPAEDER LLP The Honorable William H. Pauley, III March 7, 2013 Page 9 the relationship. Shih introduced David and his partner Rod McKay to Daugerdas, and they began doing business. As the Court knows, Deutsche Bank's participation in the tax shelters was approved at the bank's highest levels. That fact, coupled with the prominence of the Jenkins firm and the knowledge that other law and accounting firms were marketing similar products, gave David comfort that the tax shelters were lawful. Like many others, he believed that Daugerdas and his partners had found a \"loophole\" that could be exploited until it was closed. From 1998 to 2001, tax shelter trades became a part of David's business. As we see it, the jury accepted the proposition that David was not a culpable participant in the overall Jenkins tax shelter scheme. His acquittal on the tax conspiracy count and the substantive tax evasion counts (and the complete acquittal of his co-defendant Craig Brubaker) confirm the point. The jury, it seems, concluded that David did not know that a lack of economic substance made the Jenkins shelters illegal. If that is correct, then David's convictions for mail fraud and tax obstruction reflect his involvement in the three \"backdating\" transactions. In each instance, trades effected in one year (e.g., 2002) were used to generate tax 5 See, e.g., Tr. 2965 (discussing letter from Irwin Mayer to Bob Price, Alex Brown's general counsel); Tr. 5678-79 (confirming that approvals from legal, credit, tax and compliance had been obtained for the Homer transaction). DOJ-OGR-00009514",
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"content": "the relationship. Shih introduced David and his partner Rod McKay to Daugerdas, and they began doing business. As the Court knows, Deutsche Bank's participation in the tax shelters was approved at the bank's highest levels. That fact, coupled with the prominence of the Jenkins firm and the knowledge that other law and accounting firms were marketing similar products, gave David comfort that the tax shelters were lawful. Like many others, he believed that Daugerdas and his partners had found a \"loophole\" that could be exploited until it was closed. From 1998 to 2001, tax shelter trades became a part of David's business. As we see it, the jury accepted the proposition that David was not a culpable participant in the overall Jenkins tax shelter scheme. His acquittal on the tax conspiracy count and the substantive tax evasion counts (and the complete acquittal of his co-defendant Craig Brubaker) confirm the point. The jury, it seems, concluded that David did not know that a lack of economic substance made the Jenkins shelters illegal. If that is correct, then David's convictions for mail fraud and tax obstruction reflect his involvement in the three \"backdating\" transactions. In each instance, trades effected in one year (e.g., 2002) were used to generate tax",
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79
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"full_text": "Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 28 of 66\n\nC. A second juror admits to disclosing during deliberations that they were a victim of sexual assault\n\nDuring his press tour, Juror No. 50 revealed in interviews that he was not alone in revealing to jurors that he was a victim of sexual assault, describing to reporter that a second juror also disclosed that they were a victim of sexual abuse.8 On January 5, the New York Times published an article confirming Juror No. 50's statement, reporting that \"a second juror described in an interview . . . having been sexually abused as a child.\"9\n\n\"This juror, who requested anonymity, said that they, too, had discussed the experience during deliberations and that the revelation had appeared to help shape the jury's discussions.\" To date, this juror has not publicly revealed their identity, and Ms. Maxwell does not know who it is.10\n\nApplicable Law\n\nI. Juror No. 50's misconduct deprived Ms. Maxwell of her constitutional right to a fair trial by an impartial jury.\n\nA. A party alleging unfairness based on undisclosed juror bias must demonstrate first, that the juror's voir dire response was false and\n\n8 https://www.dailymail.co.uk/news/article-10379445/Ghislainc-Maxwells-lawyers-fought-ask-jurors-detailed-questions-sexual-abuse.html\n\n9 https://www.nytimes.com/2022/01/05/nyregion/maxwell-trial-jury-inquiry.html\n\n10\n\n21\n\nDOJ-OGR-00009720",
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"content": "During his press tour, Juror No. 50 revealed in interviews that he was not alone in revealing to jurors that he was a victim of sexual assault, describing to reporter that a second juror also disclosed that they were a victim of sexual abuse.8 On January 5, the New York Times published an article confirming Juror No. 50's statement, reporting that \"a second juror described in an interview . . . having been sexually abused as a child.\"9\n\n\"This juror, who requested anonymity, said that they, too, had discussed the experience during deliberations and that the revelation had appeared to help shape the jury's discussions.\" To date, this juror has not publicly revealed their identity, and Ms. Maxwell does not know who it is.10",
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"content": "Applicable Law",
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"content": "I. Juror No. 50's misconduct deprived Ms. Maxwell of her constitutional right to a fair trial by an impartial jury.",
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"content": "A. A party alleging unfairness based on undisclosed juror bias must demonstrate first, that the juror's voir dire response was false and",
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"content": "8 https://www.dailymail.co.uk/news/article-10379445/Ghislainc-Maxwells-lawyers-fought-ask-jurors-detailed-questions-sexual-abuse.html\n\n9 https://www.nytimes.com/2022/01/05/nyregion/maxwell-trial-jury-inquiry.html\n\n10",
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}

87
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"full_text": "UNITED STATES OF AMERICA, v. PAUL M. DAUGERDAS, ET AL.,\nFebruary 15, 2012\nPage 101\nC2frdau3\n1 witness, we would have otherwise called Ms. Conrad in order to\n2 elicit these facts, so somebody looking back on this record\n3 later on has no misimpression of a defendant calling a witness\n4 who the government selectively decides to immunize. We were\n5 going to call this witness ourselves. We made a decision that\n6 her testimony is in the public interest; that's why we are\n7 seeking the immunity. I just wanted to make that clear to your\n8 Honor.\n9 THE COURT: Fine. Ms. Sternheim, if you would like,\n10 you may take a seat in the jury box during her examination.\n11 MS. STERNHEIM: Thank you, Judge.\n12 THE COURT: Let's bring out Ms. Conrad.\n13 MS. STERNHEIM: Your Honor, may I take the seat\n14 closest?\n15 THE DEFENDANT: Yes, come on down.\n16 CATHERINE M. CONRAD,\n17 called as a witness by the defendant,\n18 having been duly sworn, testified as follows:\n19 THE COURT: Would you take a seat and state your full\n20 name and spell your name slowly for the court reporter.\n21 THE WITNESS: Catherine with a C,C-A-T-H-E-R-I-N-E,\n22 Conrad, C-O-N-R-A-D.\n23 THE COURT: Mr. Gair, you may inquire.\n24 DIRECT EXAMINATION\n25 BY MR. GAIR:\n...\n(Continued on next page)\nPage 101 - Page 104 (26)\nSOUTHERN DISTRICT REPORTERS",
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"full_text": "C2GFDAU1 Brune - direct 287\n1 lawyers who choose not to practice. What I was very focused on\n2 was her highest level of education that did not include any law\n3 school.\n4 Q. You said that you found out more on May 18th?\n5 A. That's right.\n6 Q. What happened on May 18th?\n7 A. Well, on May 15th while I was out of the country, Ms.\n8 Trzaskoma handled the telephone conference with the Court where\n9 this issue was first raised. Is this right? Is this right?\n10 No. I'm wrong. What I'm talking about, the first time I\n11 learned about the voir dire is I think July 18th. What I'm\n12 trying to say is that --\n13 Q. Could I stop you there? Because I'm trying to keep in\n14 somewhat chronological order.\n15 A. I'm sorry, I got it wrong what I said earlier. What I'm\n16 trying to say is I learned about the Westlaw report after that\n17 conference with the Court that Ms. Trzaskoma handled so I think\n18 that puts us to July 18th.\n19 Q. All right, so now that we've got the days straightened\n20 out --\n21 A. Sorry about that.\n22 Q. You said a moment ago that Ms. Edelstein is the kind of\n23 person who wants to see documents, cases.\n24 A. She's a very thorough person.\n25 Q. Did she ask to see the suspension opinion that had been\n (212) 805-0300\nSOUTHERN DISTRICT REPORTERS, P.C.",
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"full_text": "C2grdau2 Brune - direct\n1 A. Yes.\n2 Q. You knew that at the time you filed the brief?\n3 A. I believed it to be so. My basis for that is when I called\n4 the other lawyers in the case to let them know what our several\n5 days of investigating in the wake of the letter made us believe\n6 could be true -- we still weren't sure but we were getting a\n7 lot surer -- they all expressed complete surprise. Based on\n8 that, I believed that we were somewhat differently situated.\n9 Although, as I think you know, we were surprised.\n10 Q. You could have filed a separate brief, correct?\n11 A. We could have, yes.\n12 Q. With an accurate statement of the facts, correct?\n13 A. We certainly could have filed a separate brief. As it\n14 turned out, because the resources were different, we took by\n15 far the laboring oar with the brief.\n16 Q. Isn't it true that on that July 22nd call you said\n17 essentially, and I can bring up the transcript if you would\n18 like to see it, that you intended to lay out the facts as it\n19 related to waiver essentially when and if the government asked?\n20 A. That is pretty much what I said. I certainly thought it\n21 was the case that the government might well raise the waiver\n22 issue. As I said, I kind of missed where this was all going.\n23 But I certainly thought the government was likely going to\n24 inquire did we know. I didn't know and I don't believe anyone\n25 else at our firm did, so I certainly planned to answer the\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00010041",
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"full_text": "C2grdau4 378\n1 Finally, in the past I asked the parties to brief what\n2 they believed might occur depending upon various rulings by the\n3 Court. It seems to me that one scenario was left out. You are\n4 not to conclude from this request that this is the Court's\n5 thinking, but I want to receive briefing on the following\n6 question.\n7 If this Court were to grant the defendants' motion for\n8 a new trial and also conclude that the defendant Parse had\n9 waived, what would be the shake-out of that in terms of Parse's\n10 ability to take that issue to the Court of Appeals at the same\n11 time that the government would be taking the underlying issue\n12 on motion for a new trial to the Court of Appeals, as is the\n13 government's right under a specific statute? I have\n14 preliminarily looked at the matter, but I'd appreciate your\n15 wisdom on the question.\n16 Are there any other issues that counsel want to raise?\n17 Mr. Shechtman?\n18 MR. SHECHTMAN: Can I try to sharpen that last\n19 question?\n20 THE COURT: Go ahead, certainly.\n21 MR. SHECHTMAN: I take it the notion would be could\n22 Mr. Parse take that appeal interlocutorily before sentencing?\n23 THE COURT: Bingo.\n24 MR. SHECHTMAN: The after one is easy. So it's really\n25 an interlocutory.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00010118",
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"full_text": "C2grdau4 379\n1 THE COURT: Right. In the end, whatever happens with\n2 respect to these matters before the Court, I think that it is\n3 in everyone's interest that they travel together wherever\n4 they're going.\n5 Are there any other matters that counsel want to raise\n6 at this time before we fix a schedule for the submission of\n7 these briefs?\n8 MR. OKULA: No, your Honor. I was just going to\n9 suggest most respectfully that perhaps if counsel for the\n10 government and defendants could confer momentarily about a\n11 proposed schedule, then we could propose one to the Court.\n12 THE COURT: That's fine with me.\n13 MR. GAIR: Judge, Mr. Okula is on vacation next week,\n14 so I'd like to suggest one week.\n15 MR. SHECHTMAN: Judge, if we might be heard?\n16 THE COURT: Go ahead.\n17 MR. SHECHTMAN: We want very much to accommodate Mr.\n18 Okula's vacation, seriously. He has suggested three weeks. I\n19 start a trial on Tuesday, a month-long trial. I fully\n20 appreciate that I have to write this brief on weekends, and I\n21 will, but an extra week would be very helpful. If we could get\n22 a month, that would be grand.\n23 THE COURT: Fine. You've got it. Do you want to file\n24 your briefs on March 16, your initial briefs, or do you want\n25 March 23?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00010119",
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"full_text": "Westlaw Page 1 80 A.D.3d 168, 913 N.Y.S.2d 187, 2010 N.Y. Slip Op. 09090 (Cite as: 80 A.D.3d 168, 913 N.Y.S.2d 187) H Supreme Court, Appellate Division, First Department, New York. In the Matter of Catherine M. CONRAD, a suspended attorney: Departmental Disciplinary Committee for the First Judicial Department, Petitioner, Catherine M. Conrad, Respondent. Dec. 9, 2010. Background: Departmental Disciplinary Committee instituted disciplinary proceedings against attorney. The Supreme Court, Appellate Division, 48 A.D.3d 187, 846 N.Y.S.2d 912, suspended attorney from practice of law for failure to respond to requests made by Committee pursuant to its investigations of complaints made against her. Committee subsequently moved for order suspending attorney on ground that she suffered from disability by reason of physical or mental infirmity or illness. Attorney cross-moved for order converting her current suspension to medical suspension nunc pro tunc and order vacating suspension and reinstating her to practice of law. Holdings: The Supreme Court, Appellate Division, held that: (1) attorney's immediate reinstatement was not warranted, and (2) attorney was required to prove her fitness to be reinstated. Suspension ordered. West Headnotes [1] Attorney and Client 45 C 61 45 Attorney and Client 45I The Office of Attorney 45I(C) Discipline 45k61 k. Reinstatement. Most Cited Cases Immediate reinstatement of suspended attorney to practice of law was not warranted; alcohol dependence rendered attorney unfit to practice law, and attorney acknowledged during her deposition that her failure to cooperate and her underlying conduct was related to alcohol dependency. N.Y.Ct.Rules, §§ 603.16(c)(1), (f). [2] Attorney and Client 45 C 61 45 Attorney and Client 45I The Office of Attorney 45I(C) Discipline 45k61 k. Reinstatement. Most Cited Cases Attorney who was suspended from practice of law due to her alcohol dependence was required to prove her fitness to be reinstated, and that burden could not be satisfied by attorney's own self-assessment; rather, evaluation by © 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. PMD 20 DOJ-OGR-00010123",
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"content": "H Supreme Court, Appellate Division, First Department, New York. In the Matter of Catherine M. CONRAD, a suspended attorney: Departmental Disciplinary Committee for the First Judicial Department, Petitioner, Catherine M. Conrad, Respondent. Dec. 9, 2010.",
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"content": "Background: Departmental Disciplinary Committee instituted disciplinary proceedings against attorney. The Supreme Court, Appellate Division, 48 A.D.3d 187, 846 N.Y.S.2d 912, suspended attorney from practice of law for failure to respond to requests made by Committee pursuant to its investigations of complaints made against her. Committee subsequently moved for order suspending attorney on ground that she suffered from disability by reason of physical or mental infirmity or illness. Attorney cross-moved for order converting her current suspension to medical suspension nunc pro tunc and order vacating suspension and reinstating her to practice of law.",
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"content": "Holdings: The Supreme Court, Appellate Division, held that: (1) attorney's immediate reinstatement was not warranted, and (2) attorney was required to prove her fitness to be reinstated. Suspension ordered.",
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"content": "West Headnotes [1] Attorney and Client 45 C 61 45 Attorney and Client 45I The Office of Attorney 45I(C) Discipline 45k61 k. Reinstatement. Most Cited Cases Immediate reinstatement of suspended attorney to practice of law was not warranted; alcohol dependence rendered attorney unfit to practice law, and attorney acknowledged during her deposition that her failure to cooperate and her underlying conduct was related to alcohol dependency. N.Y.Ct.Rules, §§ 603.16(c)(1), (f).",
"position": "middle"
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"content": "[2] Attorney and Client 45 C 61 45 Attorney and Client 45I The Office of Attorney 45I(C) Discipline 45k61 k. Reinstatement. Most Cited Cases Attorney who was suspended from practice of law due to her alcohol dependence was required to prove her fitness to be reinstated, and that burden could not be satisfied by attorney's own self-assessment; rather, evaluation by",
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99
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{
"document_metadata": {
"page_number": "2",
"document_number": "A-5841",
"date": "2010",
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"full_text": "80 A.D.3d 168, 913 N.Y.S.2d 187, 2010 N.Y. Slip Op. 09090 (Cite as: 80 A.D.3d 168, 913 N.Y.S.2d 187) mental health provider attesting to attorney's current fitness to re-commence practice of law was necessary. N.Y.Ct.Rules, § 603.16(c)(1), (f). **188 Alan W. Friedberg, Chief Counsel, Departmental Disciplinary Committee, New York (Kevin E.F. O'Sullivan, of counsel), for petitioner. Victor M. Serby, for respondent. DAVID B. SAXE, Justice Presiding, DAVID FRIEDMAN, JOHN W. SWEENY, JR., EUGENE NARDELLI, JAMES M. McGUIRE, Justices. PER CURIAM. *169 Respondent Catherine M. Conrad was admitted to the practice of law in the State of New York by the Second Judicial Department on January 26, 2000, and, at all times relevant to this proceeding, has maintained an office for the practice of law within the First Judicial Department. In a previous order dated December 18, 2007, this Court suspended respondent from the practice of law for failure to respond to requests made by the Departmental Disciplinary Committee pursuant to its investigation of two complaints made against her (22 NYCRR 603.4[e][1][i]). After receiving a response by respondent six months later seeking an opportunity to respond to the complaints, the Committee conducted an investigation. Based upon respondent's admitted problem with alcohol dependency, which she acknowledged was connected to her failure to cooperate and the underlying conduct, the Committee obtained a psychiatric evaluation of respondent in November 2009, and a subsequent re-evaluation in May 2010. The psychiatrist determined that respondent's prognosis is good, but did not go as far as to assert that she is now fit to re-commence the practice of law. The Departmental Disciplinary Committee now moves for an order suspending respondent from the practice of law on the ground that she suffers from a \"disability by reason of physical or mental infirmity or illness\" (22 NY-CRR 603.16[c][1]). In her cross motion respondent seeks to convert the current suspension nunc pro tunc, but further seeks an order vacating the suspension and reinstating her to the practice of law, due to her year-long sobriety. The Committee's motion, and the first branch of respondent's cross motion, are granted to the extent that the prior finding of non-cooperation is vacated and an order **189 of suspension based upon the attorney's medical disability is granted (see Matter of Kaplan, 65 A.D.3d 287, 883 N.Y.S.2d 182 [2009]; Matter of Fusco, 18 A.D.3d 81, 798 N.Y.2d 364 [2005]). [1][2] However, that branch of respondent's cross motion seeking immediate reinstatement is denied at this time. The cross motion itself concedes the existence of the alcohol dependence rendering her unfit to practice law; additionally, she acknowledged during her deposition that her failure to cooperate was related to alcohol dependency. To support her cross motion, respondent implies that the examining psychiatrist failed to satisfy an obligation to establish that she continues to be unfit to resume her practice. However, to be entitled to reinstatement, since the initial infirmity has been conceded, it is respondent who must prove her fitness to be reinstated (see 22 NYCRR 603.16[f]), and that burden is not satisfied here by her own self-assessment (see Matter of Stewart, 47 A.D.3d 84, 846 N.Y.S.2d 13 [2007]). The branch of respondent's cross motion seeking reinstatement to the practice of law therefore must be denied at this time, without prejudice to a further application, supported by an evaluation by a mental health provider attesting to her current fitness to re-commence the practice of law (see Matter of Supino, 23 A.D.3d 11, 14, 806 N.Y.S.2d 178 [2005]). Accordingly, the Committee's motion and respondent's cross motion should be granted to the extent that the prior or order's finding of non-cooperation is vacated, and respondent is suspended from the practice of law for an indef- © 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. 6-2 DOJ-OGR-00010124",
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"type": "printed",
"content": "**188 Alan W. Friedberg, Chief Counsel, Departmental Disciplinary Committee, New York (Kevin E.F. O'Sullivan, of counsel), for petitioner. Victor M. Serby, for respondent.",
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{
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"content": "*169 Respondent Catherine M. Conrad was admitted to the practice of law in the State of New York by the Second Judicial Department on January 26, 2000, and, at all times relevant to this proceeding, has maintained an office for the practice of law within the First Judicial Department.",
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"content": "Accordingly, the Committee's motion and respondent's cross motion should be granted to the extent that the prior or order's finding of non-cooperation is vacated, and respondent is suspended from the practice of law for an indef-",
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}

83
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"full_text": "80 A.D.3d 168, 913 N.Y.S.2d 187, 2010 N.Y. Slip Op. 09090 (Cite as: 80 A.D.3d 168, 913 N.Y.S.2d 187) nite period until further order of this Court, nunc pro tunc to December 18, 2007, and the branch of respondent's cross motion seeking reinstatement to the practice of law should be denied without prejudice to a further motion for the same relief, supported by an expert's evaluation attesting to her present fitness to practice law. Respondent suspended from the practice of law in the State of New York for an indefinite period until further order of this Court, effective nunc pro tunc to December 18, 2007. Cross motion denied, without prejudice to a further motion, as indicated. So much of the Opinion Per Curiam and order of this Court entered on December 18, 2007 (M-4837) incorporating a finding of non-cooperation vacated, as indicated. All concur. N.Y.A.D. 1 Dept.,2010. In re Conrad 80 A.D.3d 168, 913 N.Y.S.2d 187, 2010 N.Y. Slip Op. 09090 END OF DOCUMENT © 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. 6-3 DOJ-OGR-00010125",
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"content": "nite period until further order of this Court, nunc pro tunc to December 18, 2007, and the branch of respondent's cross motion seeking reinstatement to the practice of law should be denied without prejudice to a further motion for the same relief, supported by an expert's evaluation attesting to her present fitness to practice law.",
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"content": "Respondent suspended from the practice of law in the State of New York for an indefinite period until further order of this Court, effective nunc pro tunc to December 18, 2007. Cross motion denied, without prejudice to a further motion, as indicated. So much of the Opinion Per Curiam and order of this Court entered on December 18, 2007 (M-4837) incorporating a finding of non-cooperation vacated, as indicated.",
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"full_text": "Case 1:09-cr-00581-WHP Document 522 Filed 04/06/12 Page 1 of 29\n\nIN THE UNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\nUNITED STATES OF AMERICA,\nPlaintiff,\nvs.\nPAUL M. DAUGERDAS, et al.,\nDefendants.\n\nCase No. S3 09 Cr. 581 (WHP)\nThe Honorable William H. Pauley, III\n\nDECLARATION OF STEPHEN GILLERS\n\nI, Stephen Gillers, under penalty of perjury, declare as follows:\n\nQualifications\n\n1. My name is Stephen Gillers. I am a law professor at New York University School of Law, where I have taught the rules and law governing lawyers and judges (\"legal ethics\") regularly since 1978. I am author of a leading casebook in the field, Regulation of Lawyers: Problems of Law and Ethics (9th ed. 2012). I have spoken hundreds of times on the subject of legal ethics at state and local bar associations nationwide and at American Bar Association meetings, at state and federal judicial conferences, and at law firms and corporate law offices in the United States and abroad. For more than a decade, I have been and remain active in the legal ethics work of the ABA's Center for Professional Responsibility, spending hundreds of hours yearly on this work. Most recently, I have been a member of the ABA's Ethics 20/20 Commission, a three and a half year project to review the rules of ethics governing lawyers in light of globalization and advance in technology. I have written widely in the area, including for law journals and the law and popular press. Legal ethics is the primary focus of my academic research. My resume is annexed as Exhibit A.\n\nQuestion Addressed And Summary Of Conclusion\n\n2. I have been asked to address the question the Court posed on February 16, 2012 - namely, \"whether the attorneys for Brune & Richard involved in this matter would have satisfied their ethical obligations if they failed to disclose the contents of the July 21 letter and their complete investigation into Juror No. 1.\" The question does not specify a time frame for any possible \"fail[ure] to disclose.\" I have been asked, therefore, to address any disclosure duty in March, May, and July of 2011. I have not been asked to address, and I am not addressing, the",
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"full_text": "Case 1:09-cr-00581-WHP Document 522 Filed 04/06/12 Page 2 of 29\n\nseparate question of whether the motion for a new trial based on the conduct of juror Conrad is meritorious. That is not a question of legal ethics.\n\n3. In summary, my opinion is that (i) the Brune & Richard lawyers had no ethical obligation to disclose the results of their March 2011 research in March, or the results of their March and May 2011 research in May; (ii) the Brune & Richard lawyers had no ethical obligation to disclose the existence or the results of their March and May research in their July 8 motion for a new trial or during the July 15 conference call with the Court; and (iii) nothing the Brune & Richard lawyers said or did in the July 8 memorandum or the July 15 conference call violated their ethical obligations.\n\nFactual Assumptions\n\n4. I have read the following documents:\n\n--Catherine Conrad's letter to the Government dated May 25, 2011;\n\n--Defendants' Brief in Support of a New Trial dated July 8, 2011;\n\n--Transcript of Telephone Conference with Court dated July 15, 2011;\n\n--Letter from Susan Brune dated July 21, 2011;\n\n--Letter from Susan Brune dated July 29, 2011;\n\n--Affidavit of Susan Brune with Exhibits (including Catherine Conrad's jury questionnaire and voir dire responses) dated September 15, 2011;\n\n--Government's Waiver Brief dated October 7, 2011;\n\n--Defendant Parse's Waiver Brief dated October 27, 2011; and\n\n--Transcript of Hearing dated February 15 and 16, 2012.\n\n5. My opinion is based on the cited documents and I assume as true the facts that emerge from the sworn testimony at the hearing held February 15 and 16, 2012. I note that the testimony at that hearing was subject to robust adverse direct examination by Government attorneys.\n\nGeneral Observations And Legal Standards\n\n6. The New York Rules of Professional Conduct (hereafter \"New York Rules\") specifically identify when a lawyer is obligated to disclose information to the Court. The New York Rules are incorporated in the local rules of this Court. See Southern District of New York Local Rule 1.5(b)(5).\n\n7. Relevant here is New York Rule 3.3(a) and (b), which provides:\n\n(a) A lawyer shall not knowingly: (1) make a false statement of fact or law to a tribunal or fail to correct a false statement of material fact or law previously",
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"content": "3. In summary, my opinion is that (i) the Brune & Richard lawyers had no ethical obligation to disclose the results of their March 2011 research in March, or the results of their March and May 2011 research in May; (ii) the Brune & Richard lawyers had no ethical obligation to disclose the existence or the results of their March and May research in their July 8 motion for a new trial or during the July 15 conference call with the Court; and (iii) nothing the Brune & Richard lawyers said or did in the July 8 memorandum or the July 15 conference call violated their ethical obligations.",
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"full_text": "Case 1:09-cr-00581-WHP Document 522 Filed 04/06/12 Page 3 of 29\nmade to the tribunal by the lawyer; (2) fail to disclose to the tribunal controlling legal authority known to the lawyer to be directly adverse to the position of the client and not disclosed by opposing counsel; or (3) offer or use evidence that the lawyer knows to be false. If a lawyer, the lawyer's client, or a witness called by the lawyer has offered material evidence and the lawyer comes to know of its falsity, the lawyer shall take reasonable remedial measures, including, if necessary, disclosure to the tribunal. A lawyer may refuse to offer evidence, other than the testimony of a defendant in a criminal matter, that the lawyer reasonably believes is false.\n(b) A lawyer who represents a client before a tribunal and who knows that a person intends to engage, is engaging or has engaged in criminal or fraudulent conduct related to the proceeding shall take reasonable remedial measures, including, if necessary, disclosure to the tribunal.\n8. Also relevant is New York Rule 3.5(d), which provides:\nA lawyer shall reveal promptly to the court improper conduct by a member of the venire or a juror, or by another toward a member of the venire or a juror or a member of his or her family of which the lawyer has knowledge.\n9. Each of these rules requires knowledge on the part of the lawyer, and that knowledge must be \"actual\" knowledge. The standard is a subjective one. New York Rule 1.0(k) contains this definition:\nKnowingly, known, know, or knows denotes actual knowledge of the fact in question. A person's knowledge may be inferred from circumstances.1\n10. A leading Second Circuit case addresses the knowledge requirement. In Doe v. Grievance Committee, 847 F.2d 57 (2nd Cir. 1988), a district judge in Connecticut disciplined a lawyer who did not report his belief that an opposing witness had lied in a deposition. The Connecticut (and the New York) rule at the time required a \"lawyer who receives information clearly establishing that...[a] person other than his client has perpetrated a fraud upon a tribunal\n1 I have also been asked to address the potential relevance of Rule 8.4(d) of the New York Rules, which says that a \"lawyer or law firm shall not...engage in conduct that is prejudicial to the administration of justice.\" This rule should not be read to expand Rule 3.3's mens rea requirement of knowledge. When the New York Rules of Professional Conduct were adopted to replace the Code of Professional Responsibility, the courts chose the standard of \"knowledge,\" the same standard as in the ABA Model Rules, to replace \"clearly established,\" which the Second Circuit had already interpreted to mean \"knowledge\" (see ¶¶ 10-11 infra). When a specific and considered rule requires knowledge, another and general rule should not be interpreted to impose a duty based on a lower standard. There would be obvious notice and fairness interests implicated in doing so.\nDOJ-OGR-00010128",
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"content": "Case 1:09-cr-00581-WHP Document 522 Filed 04/06/12 Page 3 of 29",
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"content": "made to the tribunal by the lawyer; (2) fail to disclose to the tribunal controlling legal authority known to the lawyer to be directly adverse to the position of the client and not disclosed by opposing counsel; or (3) offer or use evidence that the lawyer knows to be false. If a lawyer, the lawyer's client, or a witness called by the lawyer has offered material evidence and the lawyer comes to know of its falsity, the lawyer shall take reasonable remedial measures, including, if necessary, disclosure to the tribunal. A lawyer may refuse to offer evidence, other than the testimony of a defendant in a criminal matter, that the lawyer reasonably believes is false.",
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"content": "(b) A lawyer who represents a client before a tribunal and who knows that a person intends to engage, is engaging or has engaged in criminal or fraudulent conduct related to the proceeding shall take reasonable remedial measures, including, if necessary, disclosure to the tribunal.",
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"content": "8. Also relevant is New York Rule 3.5(d), which provides:",
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"content": "A lawyer shall reveal promptly to the court improper conduct by a member of the venire or a juror, or by another toward a member of the venire or a juror or a member of his or her family of which the lawyer has knowledge.",
"position": "main body"
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{
"type": "printed",
"content": "9. Each of these rules requires knowledge on the part of the lawyer, and that knowledge must be \"actual\" knowledge. The standard is a subjective one. New York Rule 1.0(k) contains this definition:",
"position": "main body"
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"content": "Knowingly, known, know, or knows denotes actual knowledge of the fact in question. A person's knowledge may be inferred from circumstances.1",
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"content": "10. A leading Second Circuit case addresses the knowledge requirement. In Doe v. Grievance Committee, 847 F.2d 57 (2nd Cir. 1988), a district judge in Connecticut disciplined a lawyer who did not report his belief that an opposing witness had lied in a deposition. The Connecticut (and the New York) rule at the time required a \"lawyer who receives information clearly establishing that...[a] person other than his client has perpetrated a fraud upon a tribunal",
"position": "main body"
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"content": "1 I have also been asked to address the potential relevance of Rule 8.4(d) of the New York Rules, which says that a \"lawyer or law firm shall not...engage in conduct that is prejudicial to the administration of justice.\" This rule should not be read to expand Rule 3.3's mens rea requirement of knowledge. When the New York Rules of Professional Conduct were adopted to replace the Code of Professional Responsibility, the courts chose the standard of \"knowledge,\" the same standard as in the ABA Model Rules, to replace \"clearly established,\" which the Second Circuit had already interpreted to mean \"knowledge\" (see ¶¶ 10-11 infra). When a specific and considered rule requires knowledge, another and general rule should not be interpreted to impose a duty based on a lower standard. There would be obvious notice and fairness interests implicated in doing so.",
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"Document 522",
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"DOJ-OGR-00010128"
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},
"additional_notes": "The document appears to be a court filing discussing legal ethics and professional conduct rules."
}

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{
"document_metadata": {
"page_number": "4",
"document_number": "522",
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"full_text": "shall promptly reveal the fraud to the tribunal. Id. at 61 (emphasis added)(quoting DR 7-102(B)(2) of the Code of Professional Responsibility). The district judge concluded that Doe had \"information clearly establishing\" deposition perjury because he had \"clear and convincing evidence of [the] witness's perjury.\" Id. Doe himself testified that \"he believed that [the] witness had lied at the deposition.\" Id. at 59.\n\n11. Without rejecting the lower court's factual finding that Doe had clear and convincing evidence of fraud on the tribunal, the Doe Court held that \"clearly establishing\" required more. It held that \"knowledge is required before the disclosure duty arises.\" Id. at 62. Clear and convincing proof, which is an objective test, did not trigger a reporting duty. That a lawyer \"strongly suspected\" fraud on the tribunal (a subjective test) was also insufficient. Id. at 63. As the Court noted:\n\nOur experience indicates that if any standard less than actual knowledge was adopted in this context [i.e., DR 7-102(B)(2)], serious consequences might follow. If attorneys were bound as part of their ethical duties to report to the court each time they strongly suspected that a witness lied, courts would be inundated with such reports. Court dockets would quickly become overburdened with conducting these collateral proceedings which would necessarily hold up the ultimate disposition of the underlying action. We do not believe that the Code's drafters intended to throw the court system into such a morass. Instead, it seems that the only reasonable conclusion is that the drafters intended disclosure of only that information which the attorney reasonably knows to be a fact and which, when combined with other facts in his knowledge, would clearly establish the existence of a fraud on the tribunal.\n\nTo interpret the rule to mean otherwise would be to require attorneys to disclose mere suspicions of fraud which are based upon incomplete information or information which may fall short of clearly establishing the existence of a fraud. We do not suggest, however, that by requiring that the attorney have actual knowledge of a fraud before he is bound to disclose it, he must wait until he has proof beyond a moral certainty that fraud has been committed. Rather, we simply conclude that he must clearly know, rather than suspect, that a fraud on the court has been committed before he brings this knowledge to the court's attention.\n\nId. Discipline was reversed.2\n\n12. In an adversary legal system like ours, mandatory disclosure rules, which operate as a check on the premises of that system, receive scrutiny and debate from the courts and the bar over their proper scope. Furthermore, American jurisdictions do not all agree on how to reconcile competing interests - those of the client, the tribunal, and the adversary. New York, like most (but not all) jurisdictions, has adopted Rules 3.3 (a) and (b) in identical or substantially\n\n2 I was the expert for Doe in the Connecticut disciplinary hearing.",
"text_blocks": [
{
"type": "printed",
"content": "shall promptly reveal the fraud to the tribunal. Id. at 61 (emphasis added)(quoting DR 7-102(B)(2) of the Code of Professional Responsibility). The district judge concluded that Doe had \"information clearly establishing\" deposition perjury because he had \"clear and convincing evidence of [the] witness's perjury.\" Id. Doe himself testified that \"he believed that [the] witness had lied at the deposition.\" Id. at 59.",
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"content": "11. Without rejecting the lower court's factual finding that Doe had clear and convincing evidence of fraud on the tribunal, the Doe Court held that \"clearly establishing\" required more. It held that \"knowledge is required before the disclosure duty arises.\" Id. at 62. Clear and convincing proof, which is an objective test, did not trigger a reporting duty. That a lawyer \"strongly suspected\" fraud on the tribunal (a subjective test) was also insufficient. Id. at 63. As the Court noted:",
"position": "top"
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{
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"content": "Our experience indicates that if any standard less than actual knowledge was adopted in this context [i.e., DR 7-102(B)(2)], serious consequences might follow. If attorneys were bound as part of their ethical duties to report to the court each time they strongly suspected that a witness lied, courts would be inundated with such reports. Court dockets would quickly become overburdened with conducting these collateral proceedings which would necessarily hold up the ultimate disposition of the underlying action. We do not believe that the Code's drafters intended to throw the court system into such a morass. Instead, it seems that the only reasonable conclusion is that the drafters intended disclosure of only that information which the attorney reasonably knows to be a fact and which, when combined with other facts in his knowledge, would clearly establish the existence of a fraud on the tribunal.",
"position": "middle"
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{
"type": "printed",
"content": "To interpret the rule to mean otherwise would be to require attorneys to disclose mere suspicions of fraud which are based upon incomplete information or information which may fall short of clearly establishing the existence of a fraud. We do not suggest, however, that by requiring that the attorney have actual knowledge of a fraud before he is bound to disclose it, he must wait until he has proof beyond a moral certainty that fraud has been committed. Rather, we simply conclude that he must clearly know, rather than suspect, that a fraud on the court has been committed before he brings this knowledge to the court's attention.",
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"content": "Id. Discipline was reversed.2",
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"content": "12. In an adversary legal system like ours, mandatory disclosure rules, which operate as a check on the premises of that system, receive scrutiny and debate from the courts and the bar over their proper scope. Furthermore, American jurisdictions do not all agree on how to reconcile competing interests - those of the client, the tribunal, and the adversary. New York, like most (but not all) jurisdictions, has adopted Rules 3.3 (a) and (b) in identical or substantially",
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"Document 522",
"A-5846",
"DR 7-102(B)(2)",
"Rules 3.3 (a) and (b)"
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{
"document_metadata": {
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"full_text": "identical form3 and it has also adopted Rule 3.5(d). These rules mandate disclosure of certain information to a court even if disclosure may harm the client and, for Rule 3.3 explicitly and Rule 3.5(d) implicitly, even if the information is protected as confidential client information. See New York Rule 3.3(c).4 But the duty arises only if the lawyer has \"actual knowledge.\"\n\n13. A second decision also recognizes the delicate balance between the adversary system and duties to a litigation opponent or the tribunal. In re Pennie & Edmonds LLP, 323 F.3d 86 (2nd Cir. 2003) was an appeal of Rule 11 sanctions. When a party seeks Rule 11 sanctions, the target of the motion has a 21-day \"safe harbor\" within which to withdraw or correct the challenged submission. If it does not, the \"mental state applicable to liability for Rule 11 sanctions is objective unreasonableness.\" Id. at 90. When, however, a court initiates a sanction proceeding, as by order to show cause, there is no safe harbor. Because the lawyer cannot take it back, Pennie & Edmonds holds that the required mental state is \"bad faith,\" a subjective test like actual knowledge. The Court explained that \"[a]ny regime of sanctions for a lawyer's role in the course of representing a client inevitably has implications for the functioning of the adversary system.\" Id. In support of its holding, the Court cited the interest of \"[a] vigorous adversary system.\" Id. at 91.\n\n14. In sum, from the perspective of a lawyer's ethical obligations, the premises of our \"vigorous adversary system\" control unless the situation is governed by an express exception in ethics rules, statutes, judicial decisions, or other law. These exceptions, which are written with appreciation of the need for precision, give lawyers notice of the duties that override their adversarial obligations. As the Supreme Court wrote in a different context in Polk County v. Dodson, 454 U.S. 312 (1981):\n\nWithin the context of our legal system, the duties of a defense lawyer are those of a personal counselor and advocate. It is often said that lawyers are \"officers of the court.\" But the Courts of Appeals are agreed that a lawyer representing a client is not, by virtue of being an officer of the court, a state actor \"under color of state law\" within the meaning of § 1983. In our system a defense lawyer characteristically opposes the designated representatives of the State. The system assumes that adversarial testing will ultimately advance the public interest in truth and fairness. But it posits that a defense lawyer best serves the public, not by acting on behalf of the State or in concert with it, but rather by advancing \"the undivided interests of his client.\"\n\nId. at 318 (footnotes omitted). The question I turn to now is whether lawyers from Brune & Richard LLP acted in violation of any of the exceptions to their duties in the adversary system by not disclosing certain information prior to their July 21, 2011, letter to the Court.\n\n3 See http://www.americanbar.org/content/dam/aba/migrated/cpr/pic/3_3.authcheckdam.pdf (last visited April 5, 2012).\n4 The ABA Model Rules do not contain Rule 3.5(d). In my view, its mandate appears duplicative of a lawyer's obligations under New York and Model Rule 3.3(b).\n\nDOJ-OGR-00010130",
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"type": "printed",
"content": "identical form3 and it has also adopted Rule 3.5(d). These rules mandate disclosure of certain information to a court even if disclosure may harm the client and, for Rule 3.3 explicitly and Rule 3.5(d) implicitly, even if the information is protected as confidential client information. See New York Rule 3.3(c).4 But the duty arises only if the lawyer has \"actual knowledge.\"",
"position": "top"
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"content": "13. A second decision also recognizes the delicate balance between the adversary system and duties to a litigation opponent or the tribunal. In re Pennie & Edmonds LLP, 323 F.3d 86 (2nd Cir. 2003) was an appeal of Rule 11 sanctions. When a party seeks Rule 11 sanctions, the target of the motion has a 21-day \"safe harbor\" within which to withdraw or correct the challenged submission. If it does not, the \"mental state applicable to liability for Rule 11 sanctions is objective unreasonableness.\" Id. at 90. When, however, a court initiates a sanction proceeding, as by order to show cause, there is no safe harbor. Because the lawyer cannot take it back, Pennie & Edmonds holds that the required mental state is \"bad faith,\" a subjective test like actual knowledge. The Court explained that \"[a]ny regime of sanctions for a lawyer's role in the course of representing a client inevitably has implications for the functioning of the adversary system.\" Id. In support of its holding, the Court cited the interest of \"[a] vigorous adversary system.\" Id. at 91.",
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"content": "14. In sum, from the perspective of a lawyer's ethical obligations, the premises of our \"vigorous adversary system\" control unless the situation is governed by an express exception in ethics rules, statutes, judicial decisions, or other law. These exceptions, which are written with appreciation of the need for precision, give lawyers notice of the duties that override their adversarial obligations. As the Supreme Court wrote in a different context in Polk County v. Dodson, 454 U.S. 312 (1981):",
"position": "middle"
},
{
"type": "printed",
"content": "Within the context of our legal system, the duties of a defense lawyer are those of a personal counselor and advocate. It is often said that lawyers are \"officers of the court.\" But the Courts of Appeals are agreed that a lawyer representing a client is not, by virtue of being an officer of the court, a state actor \"under color of state law\" within the meaning of § 1983. In our system a defense lawyer characteristically opposes the designated representatives of the State. The system assumes that adversarial testing will ultimately advance the public interest in truth and fairness. But it posits that a defense lawyer best serves the public, not by acting on behalf of the State or in concert with it, but rather by advancing \"the undivided interests of his client.\"",
"position": "middle"
},
{
"type": "printed",
"content": "Id. at 318 (footnotes omitted). The question I turn to now is whether lawyers from Brune & Richard LLP acted in violation of any of the exceptions to their duties in the adversary system by not disclosing certain information prior to their July 21, 2011, letter to the Court.",
"position": "middle"
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{
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{
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"content": "4 The ABA Model Rules do not contain Rule 3.5(d). In my view, its mandate appears duplicative of a lawyer's obligations under New York and Model Rule 3.3(b).",
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}

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{
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"full_text": "Case 1:09-cr-00581-WHP Document 522 Filed 04/06/12 Page 6 of 29\n\nDISCUSSION\n\nEvents in March 2011\n\n15. The Brune & Richard lawyers had no duty to reveal to the court Trzaskoma's discovery of a 2010 court order suspending a Bronx lawyer with the same name as juror Conrad. None of the lawyers had knowledge that the Bronx lawyer and juror Conrad were the same person. None even had \"clear and convincing\" evidence or \"strongly suspected\" - the objective and subjective tests Doe rejected - they were the same person. Trzaskoma and Brune (who was told of the discovery though not shown the suspension order that Trzaskoma discovered but did not print) resolved to await juror Conrad's voir dire answers. Those answers, including juror Conrad's Bronxville address, directly contradicted any identity between the juror and the lawyer. This was in fact compelling. If the sworn answers were true, the juror was not the lawyer. A contrary conclusion would require the lawyers to believe that a suspended lawyer would repeatedly perjure herself in federal court in order to sit on a jury.\n\nEvents in May 2011\n\n16. Juror Conrad gave the Court a note asking if the jury was going to be instructed on vicarious liability and respondeat superior. The contents of the note led Trzaskoma, assisted by others at the firm, to take another look at the issue the next day. The 2010 suspension order and an earlier suspension order from 2007 were found. Both identified a Bronx lawyer. A paralegal discovered the Westlaw profile and forwarded it to Trzaskoma in an email that highlighted selected information. After seeing the selected information but before reviewing the entire profile, Trzaskoma wrote \"Jesus, I do think it's her,\" but then, after reviewing the entire profile, changed her mind in light of the contradiction between the juror's voir dire answers and the limited information about lawyer Conrad (different levels of education, different addresses, etc.). In addition, Trzaskoma did not believe that the given age of the Bronx lawyer agreed with the apparent age of juror Conrad.\n\n17. Trzaskoma discussed the issue with Brune and Edelstein later in the day. All three concluded that juror Conrad was not the suspended lawyer. Co-counsel with whom the matter was thereafter informally discussed thought the question not worth pursuing. Because the Brune & Richard lawyers did not believe - let alone have actual knowledge - that the juror and the suspended lawyer were the same person, they did not present their information to the Court. At least five lawyers, based on what they had seen or been told, reached this conclusion.\n\n18. At this time, as earlier, no Brune & Richard lawyer had actual knowledge that juror Conrad was lawyer Conrad. Actual knowledge is the mental state that creates the disclosure duty under New York Rules 3.3(b) and 3.5(d). There was no ethical duty to reveal a suspicion, even a strong suspicion.\n\n19. Any notion that silence was intended to preserve undetected a basis for a new trial motion in the event of conviction is belied by the lawyers' actions. There was no effort to seek a new",
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"content": "15. The Brune & Richard lawyers had no duty to reveal to the court Trzaskoma's discovery of a 2010 court order suspending a Bronx lawyer with the same name as juror Conrad. None of the lawyers had knowledge that the Bronx lawyer and juror Conrad were the same person. None even had \"clear and convincing\" evidence or \"strongly suspected\" - the objective and subjective tests Doe rejected - they were the same person. Trzaskoma and Brune (who was told of the discovery though not shown the suspension order that Trzaskoma discovered but did not print) resolved to await juror Conrad's voir dire answers. Those answers, including juror Conrad's Bronxville address, directly contradicted any identity between the juror and the lawyer. This was in fact compelling. If the sworn answers were true, the juror was not the lawyer. A contrary conclusion would require the lawyers to believe that a suspended lawyer would repeatedly perjure herself in federal court in order to sit on a jury.",
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"content": "16. Juror Conrad gave the Court a note asking if the jury was going to be instructed on vicarious liability and respondeat superior. The contents of the note led Trzaskoma, assisted by others at the firm, to take another look at the issue the next day. The 2010 suspension order and an earlier suspension order from 2007 were found. Both identified a Bronx lawyer. A paralegal discovered the Westlaw profile and forwarded it to Trzaskoma in an email that highlighted selected information. After seeing the selected information but before reviewing the entire profile, Trzaskoma wrote \"Jesus, I do think it's her,\" but then, after reviewing the entire profile, changed her mind in light of the contradiction between the juror's voir dire answers and the limited information about lawyer Conrad (different levels of education, different addresses, etc.). In addition, Trzaskoma did not believe that the given age of the Bronx lawyer agreed with the apparent age of juror Conrad.",
"position": "middle"
},
{
"type": "printed",
"content": "17. Trzaskoma discussed the issue with Brune and Edelstein later in the day. All three concluded that juror Conrad was not the suspended lawyer. Co-counsel with whom the matter was thereafter informally discussed thought the question not worth pursuing. Because the Brune & Richard lawyers did not believe - let alone have actual knowledge - that the juror and the suspended lawyer were the same person, they did not present their information to the Court. At least five lawyers, based on what they had seen or been told, reached this conclusion.",
"position": "middle"
},
{
"type": "printed",
"content": "18. At this time, as earlier, no Brune & Richard lawyer had actual knowledge that juror Conrad was lawyer Conrad. Actual knowledge is the mental state that creates the disclosure duty under New York Rules 3.3(b) and 3.5(d). There was no ethical duty to reveal a suspicion, even a strong suspicion.",
"position": "middle"
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{
"type": "printed",
"content": "19. Any notion that silence was intended to preserve undetected a basis for a new trial motion in the event of conviction is belied by the lawyers' actions. There was no effort to seek a new",
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},
"additional_notes": "The document appears to be a court filing discussing a legal case involving a juror named Conrad and a lawyer with the same name who was suspended. The text is printed and there are no visible stamps or handwritten notes."
}

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"full_text": "Case 1:09-cr-00581-WHP Document 522 Filed 04/06/12 Page 7 of 29\n\ntrial based on juror misconduct (nor did the firm give any consideration to that possibility) from the time of the verdict and until after receipt on June 20 of juror Conrad's letter to the prosecutor and the ensuing investigation.\n\nEvents in July 2011\n\nThe July 8 Memorandum of Law\n\n20. The memorandum does not reference the discoveries in March or May. There was no duty to do so. I accept that the Brune & Richard lawyers could anticipate a possible waiver claim and could see how the government could cite the information that they had in March and May to bolster that claim. But the lawyer ethics rules impose no general duty to volunteer information that an opponent might use to support its argument and the exceptions in the rules cited do not create one specifically.5\n\n21. To put it otherwise, in order to find a duty to reveal there must be a source of the duty. Professional conduct rules do impose duties to reveal, but they do so in a way that gives lawyers notice of their requirements. No rule required disclosure of the information discovered in March or May. Any such rule would have to specify the information required to be revealed and the level of confidence in the accuracy of that information. Here, the rules imposing a duty to disclose to the tribunal are Rules 3.3(b) and 3.5(d). These rules use actual knowledge as the level of confidence required for the duty to disclosure. The information the lawyers had about the material they had gathered in March and May negates actual knowledge; the actions of the lawyers were consistent only with a conclusion of a lack of actual knowledge. In sum, only if the lawyers had had actual knowledge in March or May would they have had to reveal that in July, and they did not have actual knowledge.\n\n22. In certain places, the memorandum contains statements that are apparently alleged to imply that the Brune & Richard lawyers did not have information about juror Conrad's identity prior to June 20, when they received a copy of her letter to the government.\n\n5 Because the premises of the adversary system are central here, instruction from the contiguous world of Rule 11 is again apt:\n\nThe primary purpose of Rule 11 is to deter baseless court filings, but this goal must be considered in light of the fact that, in an adversary system of litigation, the essence of the lawyer's task is to present issues of facts and law \"as favorably as fairly possible\" in support of the client's claim. See United Nat. Ins. Co. v. R & D Latex Corp., 242 F.3d 1102, 1115 (9th Cir. 2001). Therefore, judges should \"impose sanctions on lawyers for their mode of advocacy only in the most egregious situations, lest lawyers be deterred from vigorous representation of their clients.\" Id. (citing Schlaifer Nance & Co., Inc. v. Estates of Warhol, 194 F.3d 323, 341 (2nd Cir. 1999).\n\nDesert Outdoor Advertising, Inc. v. City of Oakland, 2009 WL 943948 at *3 (N.D. Cal. Apr. 7 2009).\n\nDOJ-OGR-00010132",
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"content": "21. To put it otherwise, in order to find a duty to reveal there must be a source of the duty. Professional conduct rules do impose duties to reveal, but they do so in a way that gives lawyers notice of their requirements. No rule required disclosure of the information discovered in March or May. Any such rule would have to specify the information required to be revealed and the level of confidence in the accuracy of that information. Here, the rules imposing a duty to disclose to the tribunal are Rules 3.3(b) and 3.5(d). These rules use actual knowledge as the level of confidence required for the duty to disclosure. The information the lawyers had about the material they had gathered in March and May negates actual knowledge; the actions of the lawyers were consistent only with a conclusion of a lack of actual knowledge. In sum, only if the lawyers had had actual knowledge in March or May would they have had to reveal that in July, and they did not have actual knowledge.",
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78
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"full_text": "23. The lawyers wrote: \"The tone and content of the letter, which were in sharp contrast to the image Conrad had projected through the trial ('always head down, taking notes'), caused defendants concern and prompted them to investigate.\" Memorandum at 9. And they later wrote: \"This is not a situation where Conrad disclosed sufficient information to warrant inquiry by counsel. Defendants had no basis to inquire whether Conrad was lying in response to each of the Court's questions.\" Memorandum at 32, n.13 (internal citation and parenthetical quote omitted).\n24. In my opinion, these statements should be seen as true, not merely literally true in a hypertechnical or crabbed sense of the word, but true as reasonably read. They do not become untrue because a reader may draw a false inference that the lawyers did not intend. The juror's letter did cause concern and did prompt an investigation, as the first quotation in the memorandum states. That statement does not disclaim a prior search, whether that prior search is called an investigation or something else. I believe that focus on the word \"investigate,\" which is not a term of art, would be misguided here. The sentence correctly describes what the letter caused the lawyers to do.\n25. The second quote focuses on the voir dire in March and is also true as reasonably read. The lawyers had concluded that the order suspending a lawyer with the same name as juror Conrad was not a \"basis\" for an inquiry into the truthfulness of juror Conrad's answers. Just the opposite. Her voir dire answers, in their view, dispelled reason for inquiry. A suspended lawyer would not lie under oath at voir dire, they reasoned, given the consequences to the lawyer's ability ever to regain admission to practice. In my opinion, this conclusion was compelling.\n26. It is also my opinion that the July 8, 2011, memorandum, taken as a whole, does not show a \"knowing[]\" violation of the provisions of Rule 3.3. It is true that even when a lawyer does not have a duty to speak, if she does speak, she may not knowingly misrepresent to a court or adversary. But an unintended inference is not a misrepresentation. The lack of disclaimer language in the memorandum's true statements - the fact that the lawyers, while focused on the new trial motion, did not anticipate what a reader might infer and what they did not mean to imply - is not an action that can support a finding of unethical behavior under the New York Rules.\n27. The lawyers understandably now wish they had not included these passages as written. Greater focus might have led them to anticipate how others might read them differently than intended, and to omit them (they were unnecessary to the motion), rephrase them, or add the history of their earlier research.\nThe July 15 Telephone Conference\n28. In the July 15 telephone conference, the Court said that it wanted to \"ascertain from each of the defendants ... whether any of them were aware of the disturbing things that have been revealed by defense on this motion concerning Juror Number One [Conrad].\" The Court invited a response on the call or via letter. Trzaskoma's response was:\nTrzaskoma: We were not aware of the facts that have come to light, and I think if your Honor deems it appropriate, we can submit a letter.\nDOJ-OGR-00010133",
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"content": "24. In my opinion, these statements should be seen as true, not merely literally true in a hypertechnical or crabbed sense of the word, but true as reasonably read. They do not become untrue because a reader may draw a false inference that the lawyers did not intend. The juror's letter did cause concern and did prompt an investigation, as the first quotation in the memorandum states. That statement does not disclaim a prior search, whether that prior search is called an investigation or something else. I believe that focus on the word \"investigate,\" which is not a term of art, would be misguided here. The sentence correctly describes what the letter caused the lawyers to do.",
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"content": "25. The second quote focuses on the voir dire in March and is also true as reasonably read. The lawyers had concluded that the order suspending a lawyer with the same name as juror Conrad was not a \"basis\" for an inquiry into the truthfulness of juror Conrad's answers. Just the opposite. Her voir dire answers, in their view, dispelled reason for inquiry. A suspended lawyer would not lie under oath at voir dire, they reasoned, given the consequences to the lawyer's ability ever to regain admission to practice. In my opinion, this conclusion was compelling.",
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"content": "26. It is also my opinion that the July 8, 2011, memorandum, taken as a whole, does not show a \"knowing[]\" violation of the provisions of Rule 3.3. It is true that even when a lawyer does not have a duty to speak, if she does speak, she may not knowingly misrepresent to a court or adversary. But an unintended inference is not a misrepresentation. The lack of disclaimer language in the memorandum's true statements - the fact that the lawyers, while focused on the new trial motion, did not anticipate what a reader might infer and what they did not mean to imply - is not an action that can support a finding of unethical behavior under the New York Rules.",
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"full_text": "Case 1:09-cr-00581-WHP Document 522 Filed 04/06/12 Page 9 of 29\n\nThe Court: All right. I do. Because I would like to make certain that any defendant who had a jury consultant on the matter also make certain that the jury consultant did not have any information on Juror Number One.\n\nTrzaskoma: The only thing additional that I would offer your Honor is—well, we can address this in a letter. I think it's more appropriate.\n\n29. This colloquy must be read in its (rather brief) entirety, that is, as a whole. Trzaskoma's statement implies that the answer to the Court's question from Brune & Richard would not be that it had no information at all. It would not require a letter to say only that. It is, instead, clear that Trzakoma had something \"additional...to offer,\" and chose to accept the Court's invitation to say it in a letter, which was done on July 21 in a fashion that adequately disclosed the firm's earlier research and internal communications on the subject. \"The general rule is that statements must be taken in context, and that related parts of a document must be taken together. That a hasty reader might take the first paragraph out of context is not in the present circumstances enough to brand the memorandum as false.\" Young v. City of Providence, 404 F.3d 33, 40-41 (1st Cir. 2005) (Rule 11 appeal) (citations omitted).\n\n30. For the reasons stated, my opinion is that the actions of the Brune & Richard lawyers throughout the trial and in the months following with respect to the information they had obtained about Catherine Conrad were entirely consistent with their responsibilities under the lawyer ethics rules.\n\nCONCLUSION\n\nStephen Gillers",
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"full_text": "Case 1:09-cr-00581-WHP Document 522 Filed 04/06/12 Page 11 of 29 Stephen Gillers [January 2012] STEPHEN GILLERS Elihu Root Professor of Law (vice dean 1999-2004) New York University School of Law 40 Washington Square South New York, NY 10012 (212) 998-6264 (tel) (212) 995-4658 (fax) stephen.gillers@nyu.edu AREAS OF TEACHING Regulation of Lawyers and Professional Responsibility Evidence; Law and Literature; Media Law PRIOR COURSES Civil Procedure, Agency, Advocacy of Civil Claims, Federal Courts PUBLICATIONS BOOKS AND ANTHOLOGIES: Regulation of Lawyers: Problems of Law and Ethics (Aspen Law & Business, 9th ed., April 2012). The first edition of this popular casebook was published in 1985. Norman Dorsen was a co-author on the first two editions. Stephen Gillers is the sole author of the third through ninth editions. The first four editions were published by Little, Brown & Co., which then sold its law book publishing operation to Aspen. Regulation of Lawyers: Statutes and Standards (with Roy Simon and Andrew Perlman) (Aspen Law & Business) This is a compilation with editorial comment. The first volume was published in 1989. Updated versions have been published annually thereafter. As of the 2009 edition, Andrew Perlman has joined as a co-editor. Regulation of the Legal Profession (Aspen 2009). This is a 400+ page book in the Aspen \"Essentials\" series explains ethics rules and laws governing American lawyers and judges. Getting Justice: The Rights of People (Basic Books, 1971; revised paperback, New American Library, May 1973). 1 DOJ-OGR-00010136",
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"full_text": "A-5854 Case 1:09-cr-00581-WHP Document 522 Filed 04/06/12 Page 12 of 29 Stephen Gillers PUBLICATIONS (continued) Investigating the FBI (co-Editor with P. Watters) (Doubleday, 1973; Ballantine, 1974) None of Your Business: Government Secrecy in America (co-Editor with N. Dorsen) (Viking, 1974; Penguin, 1975). I'd Rather Do It Myself: How to Set Up Your Own Law Firm (Law Journal Press, 1977). Looking At Law School: A Student Guide From the Society of American Law Teachers (editor and contributor) (Taplinger, 1977; NAL, 1977; revised ed., NAL, 1984; third ed., NAL, 1990). The Rights of Lawyers and Clients (Avon, 1979). \"Four Policemen in London and Amsterdam,\" in R. Schrank (ed.) American Workers Abroad (MIT Press, 1979). \"Dispute Resolution in Prison: The California Experience,\" and \"New Faces in the Neighborhood Mediating the Forest Hills Housing Dispute,\" both in R. Goldmann (ed.) Roundtable Justice: Case Studies in Conflict Resolution (Westview Press, 1980). \"The American Legal Profession,\" in A. Morrison (ed.), Fundamentals of American Law (Oxford University Press 1996). The Elsinore Appeal: People v. Hamlet (St. Martin's Press 1996). This book contains the text of Hamlet together with briefs and oral argument for and against affirmance of Prince Hamlet's (imaginary) murder convictions. The book arose out of a symposium sponsored by the Association of the Bar of the City of New York. \"In the Pink Room,\" in Legal Ethics: Law Stories (D. Rhode & D. Luban, eds.) (Foundation Press, 2006) (also published as a freestanding monograph). ARTICLES: Guns, Fruit, Drugs, and Documents: A Criminal Defense Lawyer's Responsibility for Real Evidence, 63 Stan. L. Rev. 813 (2011) Is Law (Still) An Honorable Profession?, 19 Professional Lawyer 23 (2009)(based on a talk at Central Synagogue in Manhattan). 2 DOJ-OGR-00010137",
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"February 28, 1986",
"April 17, 1986",
"May/June 1986",
"June 2, 1986",
"July 19-26, 1986",
"September 10, 1986",
"August 31, 1986",
"November 10, 1986",
"November 12, 1986",
"November 13, 1986",
"November 23, 1986",
"February 21, 1987",
"May 18, 1987",
"June 1, 1987",
"November 8, 1987",
"November 11, 1987",
"December 21, 1987",
"May 1, 1988",
"June 1, 1988",
"04/06/12"
],
"reference_numbers": [
"Case 1:09-cr-00581-WHP",
"Document 522",
"DOJ-OGR-00010147"
]
},
"additional_notes": "The document appears to be a court filing with a list of references related to legal ethics and lawyer discipline. The text is clear and legible, with no visible redactions or damage."
}

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{
"document_metadata": {
"page_number": "23",
"document_number": "522",
"date": "04/06/12",
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"full_text": "Case 1:09-cr-00581-WHP Document 522 Filed 04/06/12 Page 23 of 29\nStephen Gillers\n35. Do Brawley Lawyers Risk Serious Discipline?, New York Law Journal, June 22, 1988.\n36. Have the Brawley Lawyers Broken the Law?, New York Times, July 2, 1988.\n37. Report Demonstrates Why Meese is Unfit to Be Attorney General, Atlanta Journal and Constitution, July 24, 1988.\n38. Ethical Questions for Prosecutors in Corporate-Crime Investigations, New York Law Journal, September 6, 1988.\n39. Restoring Faith at Justice, National Law Journal, November 21, 1988.\n40. Is Bush Repeating Rockefeller's Folly?, New York Times, September 11, 1989.\n41. Standards Time, The Nation, January 29, 1990 (on the subject of legislative ethics).\n42. Abused Children vs. The Bill of Rights, New York Times, August 3, 1990.\n43. Words Into Deeds: Counselor, Can You Spare a Buck?, ABA Journal, November 1990.\n44. Bad Apples, ABA Journal at 96 (March 1991) (book review).\n45. The Gotti Lawyers and the Sixth Amendment, New York Law Journal, August 12, 1991.\n46. Justice or Just Us? The Door to Dan Quayle's Courthouse Only Swings One Way, ABA Journal (June 1992) at 109.\n47. Fighting Words (What was once comical is now costly), ABA Journal (August 1992) at 102.\n48. Sensitivity Training: A New Way to Sharpen Your Skills At Spotting Ethics Conflicts, ABA Journal (October 1992) at 107.\n49. Under Color of Law: Second Circuit Expands Section 1983 Liability for Government Lawyers, ABA Journal (December 1992) at 121.\n50. Cleaning Up the S&L Mess: Courts Are Taking the Duty to Investigate Seriously, ABA Journal (February 1993) at 93.\n51. All Non-Refundable Fee Agreements Are Not Created Equal, New York Law Journal (February 3, 1993) at 1. (Analyzing appellate decision prohibiting non-refundable fees.)\n52. The Packwood Case: The Senate Is Also on Trial, The Nation (March 29, 1993) at 404.\n53. Conflict of Laws: Real-World Rules for Interstate Regulation of Practice, ABA Journal (April 1993) at 111.\n13\nDOJ-OGR-00010148",
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"content": "Stephen Gillers",
"position": "header"
},
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"type": "printed",
"content": "35. Do Brawley Lawyers Risk Serious Discipline?, New York Law Journal, June 22, 1988.\n36. Have the Brawley Lawyers Broken the Law?, New York Times, July 2, 1988.\n37. Report Demonstrates Why Meese is Unfit to Be Attorney General, Atlanta Journal and Constitution, July 24, 1988.\n38. Ethical Questions for Prosecutors in Corporate-Crime Investigations, New York Law Journal, September 6, 1988.\n39. Restoring Faith at Justice, National Law Journal, November 21, 1988.\n40. Is Bush Repeating Rockefeller's Folly?, New York Times, September 11, 1989.\n41. Standards Time, The Nation, January 29, 1990 (on the subject of legislative ethics).\n42. Abused Children vs. The Bill of Rights, New York Times, August 3, 1990.\n43. Words Into Deeds: Counselor, Can You Spare a Buck?, ABA Journal, November 1990.\n44. Bad Apples, ABA Journal at 96 (March 1991) (book review).\n45. The Gotti Lawyers and the Sixth Amendment, New York Law Journal, August 12, 1991.\n46. Justice or Just Us? The Door to Dan Quayle's Courthouse Only Swings One Way, ABA Journal (June 1992) at 109.\n47. Fighting Words (What was once comical is now costly), ABA Journal (August 1992) at 102.\n48. Sensitivity Training: A New Way to Sharpen Your Skills At Spotting Ethics Conflicts, ABA Journal (October 1992) at 107.\n49. Under Color of Law: Second Circuit Expands Section 1983 Liability for Government Lawyers, ABA Journal (December 1992) at 121.\n50. Cleaning Up the S&L Mess: Courts Are Taking the Duty to Investigate Seriously, ABA Journal (February 1993) at 93.\n51. All Non-Refundable Fee Agreements Are Not Created Equal, New York Law Journal (February 3, 1993) at 1. (Analyzing appellate decision prohibiting non-refundable fees.)\n52. The Packwood Case: The Senate Is Also on Trial, The Nation (March 29, 1993) at 404.\n53. Conflict of Laws: Real-World Rules for Interstate Regulation of Practice, ABA Journal (April 1993) at 111.",
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"entities": {
"people": [
"Meese",
"Bush",
"Rockefeller",
"Brawley",
"Dan Quayle",
"Gotti",
"Packwood"
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"organizations": [
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"Atlanta Journal and Constitution",
"National Law Journal",
"The Nation",
"ABA Journal"
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"locations": [
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"dates": [
"June 22, 1988",
"July 2, 1988",
"July 24, 1988",
"September 6, 1988",
"November 21, 1988",
"September 11, 1989",
"January 29, 1990",
"August 3, 1990",
"November 1990",
"March 1991",
"August 12, 1991",
"June 1992",
"August 1992",
"October 1992",
"December 1992",
"February 1993",
"February 3, 1993",
"March 29, 1993",
"April 1993",
"04/06/12"
],
"reference_numbers": [
"1:09-cr-00581-WHP",
"Document 522",
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},
"additional_notes": "The document appears to be a court filing with a list of references or bibliography related to legal ethics and practices. The text is printed and legible. There are no visible stamps or handwritten notes."
}

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