mirror of
https://github.com/epstein-docs/epstein-docs.github.io.git
synced 2025-12-09 19:46:33 -06:00
initial
This commit is contained in:
commit
f63bc71826
216
.eleventy.js
Normal file
216
.eleventy.js
Normal file
@ -0,0 +1,216 @@
|
||||
const fs = require('fs');
|
||||
const path = require('path');
|
||||
|
||||
module.exports = function(eleventyConfig) {
|
||||
// Copy results directory to output
|
||||
eleventyConfig.addPassthroughCopy({ "./results": "documents" });
|
||||
|
||||
// Cache the documents data - only compute once
|
||||
let cachedDocuments = null;
|
||||
|
||||
function getDocuments() {
|
||||
if (cachedDocuments) {
|
||||
return cachedDocuments;
|
||||
}
|
||||
const resultsDir = path.join(__dirname, './results');
|
||||
const pages = [];
|
||||
|
||||
function readDocuments(dir, relativePath = '') {
|
||||
const entries = fs.readdirSync(dir, { withFileTypes: true });
|
||||
|
||||
for (const entry of entries) {
|
||||
const fullPath = path.join(dir, entry.name);
|
||||
const relPath = path.join(relativePath, entry.name);
|
||||
|
||||
if (entry.isDirectory()) {
|
||||
readDocuments(fullPath, relPath);
|
||||
} else if (entry.name.endsWith('.json')) {
|
||||
try {
|
||||
const content = JSON.parse(fs.readFileSync(fullPath, 'utf8'));
|
||||
pages.push({
|
||||
path: relPath,
|
||||
filename: entry.name.replace('.json', ''),
|
||||
folder: relativePath || 'root',
|
||||
...content
|
||||
});
|
||||
} catch (e) {
|
||||
console.error(`Error reading ${fullPath}:`, e.message);
|
||||
}
|
||||
}
|
||||
}
|
||||
}
|
||||
|
||||
readDocuments(resultsDir);
|
||||
|
||||
// Normalize function to handle LLM inconsistencies in document numbers
|
||||
const normalizeDocNum = (docNum) => {
|
||||
if (!docNum) return null;
|
||||
// Convert to lowercase, remove all non-alphanumeric except hyphens, collapse multiple hyphens
|
||||
return String(docNum)
|
||||
.toLowerCase()
|
||||
.replace(/[^a-z0-9-]/g, '-')
|
||||
.replace(/-+/g, '-')
|
||||
.replace(/^-+|-+$/g, '');
|
||||
};
|
||||
|
||||
// Group pages by NORMALIZED document_number to handle LLM variations
|
||||
const documentMap = new Map();
|
||||
|
||||
pages.forEach(page => {
|
||||
// Use document_number from metadata to group pages of the same document
|
||||
const rawDocNum = page.document_metadata?.document_number;
|
||||
|
||||
// Skip pages without a document number
|
||||
if (!rawDocNum) {
|
||||
console.warn(`Page ${page.filename} has no document_number, using filename as fallback`);
|
||||
const fallbackKey = normalizeDocNum(page.filename) || page.filename;
|
||||
if (!documentMap.has(fallbackKey)) {
|
||||
documentMap.set(fallbackKey, []);
|
||||
}
|
||||
documentMap.get(fallbackKey).push(page);
|
||||
return;
|
||||
}
|
||||
|
||||
// Normalize the document number to group variants together
|
||||
const normalizedDocNum = normalizeDocNum(rawDocNum);
|
||||
|
||||
if (!documentMap.has(normalizedDocNum)) {
|
||||
documentMap.set(normalizedDocNum, []);
|
||||
}
|
||||
documentMap.get(normalizedDocNum).push(page);
|
||||
});
|
||||
|
||||
// Convert to array and sort pages within each document
|
||||
const documents = Array.from(documentMap.entries()).map(([normalizedDocNum, docPages]) => {
|
||||
|
||||
// Sort pages by page number
|
||||
docPages.sort((a, b) => {
|
||||
const pageA = parseInt(a.document_metadata?.page_number) || 0;
|
||||
const pageB = parseInt(b.document_metadata?.page_number) || 0;
|
||||
return pageA - pageB;
|
||||
});
|
||||
|
||||
// Combine all entities from all pages
|
||||
const allEntities = {
|
||||
people: new Set(),
|
||||
organizations: new Set(),
|
||||
locations: new Set(),
|
||||
dates: new Set(),
|
||||
reference_numbers: new Set()
|
||||
};
|
||||
|
||||
docPages.forEach(page => {
|
||||
if (page.entities) {
|
||||
Object.keys(allEntities).forEach(key => {
|
||||
if (page.entities[key]) {
|
||||
page.entities[key].forEach(item => allEntities[key].add(item));
|
||||
}
|
||||
});
|
||||
}
|
||||
});
|
||||
|
||||
// Get metadata from first page
|
||||
const firstPage = docPages[0];
|
||||
|
||||
// Get all unique folders that contain pages of this document
|
||||
const folders = [...new Set(docPages.map(p => p.folder))];
|
||||
|
||||
// Get all unique raw document numbers (for display)
|
||||
const rawDocNums = [...new Set(docPages.map(p => p.document_metadata?.document_number).filter(Boolean))];
|
||||
|
||||
return {
|
||||
unique_id: normalizedDocNum, // Normalized version for unique URLs
|
||||
document_number: rawDocNums.length === 1 ? rawDocNums[0] : normalizedDocNum, // Show original if consistent, else normalized
|
||||
raw_document_numbers: rawDocNums, // All variations found
|
||||
pages: docPages,
|
||||
page_count: docPages.length,
|
||||
document_metadata: firstPage.document_metadata,
|
||||
entities: {
|
||||
people: Array.from(allEntities.people),
|
||||
organizations: Array.from(allEntities.organizations),
|
||||
locations: Array.from(allEntities.locations),
|
||||
dates: Array.from(allEntities.dates),
|
||||
reference_numbers: Array.from(allEntities.reference_numbers)
|
||||
},
|
||||
full_text: docPages.map(p => p.full_text).join('\n\n--- PAGE BREAK ---\n\n'),
|
||||
folder: folders.join(', '), // Show all folders if document spans multiple
|
||||
folders: folders // Keep array for reference
|
||||
};
|
||||
});
|
||||
|
||||
cachedDocuments = documents;
|
||||
return documents;
|
||||
}
|
||||
|
||||
// Add global data - load all pages and group into documents
|
||||
eleventyConfig.addGlobalData("documents", getDocuments);
|
||||
|
||||
// Build indices from grouped documents
|
||||
eleventyConfig.addGlobalData("indices", () => {
|
||||
const documentsData = getDocuments();
|
||||
|
||||
const people = new Map();
|
||||
const organizations = new Map();
|
||||
const locations = new Map();
|
||||
const dates = new Map();
|
||||
const documentTypes = new Map();
|
||||
|
||||
documentsData.forEach(doc => {
|
||||
// People
|
||||
if (doc.entities?.people) {
|
||||
doc.entities.people.forEach(person => {
|
||||
if (!people.has(person)) people.set(person, []);
|
||||
people.get(person).push(doc);
|
||||
});
|
||||
}
|
||||
|
||||
// Organizations
|
||||
if (doc.entities?.organizations) {
|
||||
doc.entities.organizations.forEach(org => {
|
||||
if (!organizations.has(org)) organizations.set(org, []);
|
||||
organizations.get(org).push(doc);
|
||||
});
|
||||
}
|
||||
|
||||
// Locations
|
||||
if (doc.entities?.locations) {
|
||||
doc.entities.locations.forEach(loc => {
|
||||
if (!locations.has(loc)) locations.set(loc, []);
|
||||
locations.get(loc).push(doc);
|
||||
});
|
||||
}
|
||||
|
||||
// Dates
|
||||
if (doc.entities?.dates) {
|
||||
doc.entities.dates.forEach(date => {
|
||||
if (!dates.has(date)) dates.set(date, []);
|
||||
dates.get(date).push(doc);
|
||||
});
|
||||
}
|
||||
|
||||
// Document types
|
||||
const docType = doc.document_metadata?.document_type;
|
||||
if (docType) {
|
||||
if (!documentTypes.has(docType)) documentTypes.set(docType, []);
|
||||
documentTypes.get(docType).push(doc);
|
||||
}
|
||||
});
|
||||
|
||||
return {
|
||||
people: Array.from(people.entries()).map(([name, docs]) => ({ name, docs, count: docs.length })).sort((a, b) => b.count - a.count),
|
||||
organizations: Array.from(organizations.entries()).map(([name, docs]) => ({ name, docs, count: docs.length })).sort((a, b) => b.count - a.count),
|
||||
locations: Array.from(locations.entries()).map(([name, docs]) => ({ name, docs, count: docs.length })).sort((a, b) => b.count - a.count),
|
||||
dates: Array.from(dates.entries()).map(([name, docs]) => ({ name, docs, count: docs.length })).sort((a, b) => b.count - a.count),
|
||||
documentTypes: Array.from(documentTypes.entries()).map(([name, docs]) => ({ name, docs, count: docs.length })).sort((a, b) => b.count - a.count)
|
||||
};
|
||||
});
|
||||
|
||||
return {
|
||||
dir: {
|
||||
input: "src",
|
||||
output: "_site",
|
||||
includes: "_includes"
|
||||
},
|
||||
pathPrefix: "/"
|
||||
};
|
||||
};
|
||||
4
.env.example
Normal file
4
.env.example
Normal file
@ -0,0 +1,4 @@
|
||||
# OpenAI-compatible API Configuration
|
||||
OPENAI_API_URL=http://....
|
||||
OPENAI_API_KEY=abcd1234
|
||||
OPENAI_MODEL=meta-llama/Llama-4-Maverick-17B-128E-Instruct
|
||||
51
.github/workflows/deploy.yml
vendored
Normal file
51
.github/workflows/deploy.yml
vendored
Normal file
@ -0,0 +1,51 @@
|
||||
name: Deploy to GitHub Pages
|
||||
|
||||
on:
|
||||
push:
|
||||
branches:
|
||||
- main
|
||||
workflow_dispatch:
|
||||
|
||||
permissions:
|
||||
contents: read
|
||||
pages: write
|
||||
id-token: write
|
||||
|
||||
concurrency:
|
||||
group: "pages"
|
||||
cancel-in-progress: false
|
||||
|
||||
jobs:
|
||||
build:
|
||||
runs-on: ubuntu-latest
|
||||
steps:
|
||||
- name: Checkout
|
||||
uses: actions/checkout@v4
|
||||
|
||||
- name: Setup Node
|
||||
uses: actions/setup-node@v4
|
||||
with:
|
||||
node-version: '20'
|
||||
cache: 'npm'
|
||||
|
||||
- name: Install dependencies
|
||||
run: npm ci
|
||||
|
||||
- name: Build with Eleventy
|
||||
run: npm run build
|
||||
|
||||
- name: Upload artifact
|
||||
uses: actions/upload-pages-artifact@v3
|
||||
with:
|
||||
path: ./_site
|
||||
|
||||
deploy:
|
||||
environment:
|
||||
name: github-pages
|
||||
url: ${{ steps.deployment.outputs.page_url }}
|
||||
runs-on: ubuntu-latest
|
||||
needs: build
|
||||
steps:
|
||||
- name: Deploy to GitHub Pages
|
||||
id: deployment
|
||||
uses: actions/deploy-pages@v4
|
||||
26
.gitignore
vendored
Normal file
26
.gitignore
vendored
Normal file
@ -0,0 +1,26 @@
|
||||
# Downloaded images
|
||||
downloads/
|
||||
|
||||
# Environment variables
|
||||
.env
|
||||
|
||||
# Dependencies
|
||||
node_modules/
|
||||
|
||||
# Build output
|
||||
_site/
|
||||
|
||||
# Python cache
|
||||
__pycache__/
|
||||
*.pyc
|
||||
*.pyo
|
||||
|
||||
# IDE
|
||||
.vscode/
|
||||
.idea/
|
||||
*.swp
|
||||
*.swo
|
||||
|
||||
# OS
|
||||
.DS_Store
|
||||
Thumbs.db
|
||||
21
LICENSE
Normal file
21
LICENSE
Normal file
@ -0,0 +1,21 @@
|
||||
MIT License
|
||||
|
||||
Copyright (c) 2025 Epstein Files Archive
|
||||
|
||||
Permission is hereby granted, free of charge, to any person obtaining a copy
|
||||
of this software and associated documentation files (the "Software"), to deal
|
||||
in the Software without restriction, including without limitation the rights
|
||||
to use, copy, modify, merge, publish, distribute, sublicense, and/or sell
|
||||
copies of the Software, and to permit persons to whom the Software is
|
||||
furnished to do so, subject to the following conditions:
|
||||
|
||||
The above copyright notice and this permission notice shall be included in all
|
||||
copies or substantial portions of the Software.
|
||||
|
||||
THE SOFTWARE IS PROVIDED "AS IS", WITHOUT WARRANTY OF ANY KIND, EXPRESS OR
|
||||
IMPLIED, INCLUDING BUT NOT LIMITED TO THE WARRANTIES OF MERCHANTABILITY,
|
||||
FITNESS FOR A PARTICULAR PURPOSE AND NONINFRINGEMENT. IN NO EVENT SHALL THE
|
||||
AUTHORS OR COPYRIGHT HOLDERS BE LIABLE FOR ANY CLAIM, DAMAGES OR OTHER
|
||||
LIABILITY, WHETHER IN AN ACTION OF CONTRACT, TORT OR OTHERWISE, ARISING FROM,
|
||||
OUT OF OR IN CONNECTION WITH THE SOFTWARE OR THE USE OR OTHER DEALINGS IN THE
|
||||
SOFTWARE.
|
||||
152
README.md
Normal file
152
README.md
Normal file
@ -0,0 +1,152 @@
|
||||
# Epstein Files Archive
|
||||
|
||||
An automatically processed, OCR'd, searchable archive of publicly released documents related to the Jeffrey Epstein case.
|
||||
|
||||
## About
|
||||
|
||||
This project automatically processes thousands of scanned document pages using AI-powered OCR to:
|
||||
- Extract and preserve all text (printed and handwritten)
|
||||
- Identify and index entities (people, organizations, locations, dates)
|
||||
- Reconstruct multi-page documents from individual scans
|
||||
- Provide a searchable web interface to explore the archive
|
||||
|
||||
**This is a public service project.** All documents are from public releases. This archive makes them more accessible and searchable.
|
||||
|
||||
## Features
|
||||
|
||||
- **Full OCR**: Extracts both printed and handwritten text from all documents
|
||||
- **Entity Extraction**: Automatically identifies and indexes:
|
||||
- People mentioned
|
||||
- Organizations
|
||||
- Locations
|
||||
- Dates
|
||||
- Reference numbers
|
||||
- **Document Reconstruction**: Groups scanned pages back into complete documents
|
||||
- **Searchable Interface**: Browse by person, organization, location, date, or document type
|
||||
- **Static Site**: Fast, lightweight, works anywhere
|
||||
|
||||
## Project Structure
|
||||
|
||||
```
|
||||
.
|
||||
├── process_images.py # Python script to OCR images using AI
|
||||
├── requirements.txt # Python dependencies
|
||||
├── .env.example # Example environment configuration
|
||||
├── downloads/ # Place document images here
|
||||
├── results/ # Extracted JSON data per document
|
||||
├── src/ # 11ty source files for website
|
||||
├── .eleventy.js # Static site generator configuration
|
||||
└── _site/ # Generated static website (after build)
|
||||
```
|
||||
|
||||
## Setup
|
||||
|
||||
### 1. Install Dependencies
|
||||
|
||||
**Python (for OCR processing):**
|
||||
```bash
|
||||
pip install -r requirements.txt
|
||||
```
|
||||
|
||||
**Node.js (for website generation):**
|
||||
```bash
|
||||
npm install
|
||||
```
|
||||
|
||||
### 2. Configure API
|
||||
|
||||
Copy `.env.example` to `.env` and configure your OpenAI-compatible API endpoint:
|
||||
|
||||
```bash
|
||||
cp .env.example .env
|
||||
# Edit .env with your API details
|
||||
```
|
||||
|
||||
### 3. Process Documents
|
||||
|
||||
Place document images in the `downloads/` directory, then run:
|
||||
|
||||
```bash
|
||||
python process_images.py
|
||||
|
||||
# Options:
|
||||
# --limit N # Process only N images (for testing)
|
||||
# --workers N # Number of parallel workers (default: 5)
|
||||
# --no-resume # Process all files, ignore index
|
||||
```
|
||||
|
||||
The script will:
|
||||
- Process each image through the OCR API
|
||||
- Extract text, entities, and metadata
|
||||
- Save results to `./results/{folder}/{imagename}.json`
|
||||
- Track progress in `processing_index.json` (resume-friendly)
|
||||
|
||||
### 4. Generate Website
|
||||
|
||||
Build the static site from the processed data:
|
||||
|
||||
```bash
|
||||
npm run build # Build static site to _site/
|
||||
npm start # Development server with live reload
|
||||
```
|
||||
|
||||
## How It Works
|
||||
|
||||
1. **Document Processing**: Images are sent to an AI vision model that extracts:
|
||||
- All text in reading order
|
||||
- Document metadata (page numbers, document numbers, dates)
|
||||
- Named entities (people, orgs, locations)
|
||||
- Text type annotations (printed, handwritten, stamps)
|
||||
|
||||
2. **Document Grouping**: Individual page scans are automatically grouped by document number and sorted by page number to reconstruct complete documents
|
||||
|
||||
3. **Static Site Generation**: 11ty processes the JSON data to create:
|
||||
- Index pages for all entities
|
||||
- Individual document pages with full text
|
||||
- Search and browse interfaces
|
||||
|
||||
## Performance
|
||||
|
||||
- Processes ~2,000 pages into ~400 multi-page documents
|
||||
- Handles LLM inconsistencies in document number formatting
|
||||
- Resume-friendly processing (skip already-processed files)
|
||||
- Parallel processing with configurable workers
|
||||
|
||||
## Contributing
|
||||
|
||||
This is an open archive project. Contributions welcome:
|
||||
- Report issues with OCR accuracy
|
||||
- Suggest UI improvements
|
||||
- Add additional document sources
|
||||
- Improve entity extraction
|
||||
|
||||
## Support This Project
|
||||
|
||||
If you find this archive useful, consider supporting its maintenance and hosting:
|
||||
|
||||
**Bitcoin**: `bc1qmahlh5eql05w30cgf5taj3n23twmp0f5xcvnnz`
|
||||
|
||||
## Deployment
|
||||
|
||||
The site is automatically deployed to GitHub Pages on every push to the main branch.
|
||||
|
||||
### GitHub Pages Setup
|
||||
|
||||
1. Push this repository to GitHub: `https://github.com/epstein-docs/epstein-docs`
|
||||
2. Go to Settings → Pages
|
||||
3. Source: GitHub Actions
|
||||
4. The workflow will automatically build and deploy the site
|
||||
|
||||
The site will be available at: `https://epstein-docs.github.io/epstein-docs/`
|
||||
|
||||
## License
|
||||
|
||||
This project is licensed under the MIT License - see the [LICENSE](LICENSE) file for details.
|
||||
|
||||
The code in this repository is open source and free to use. The documents themselves are public records.
|
||||
|
||||
**Repository**: https://github.com/epstein-docs/epstein-docs
|
||||
|
||||
## Disclaimer
|
||||
|
||||
This is an independent archival project. Documents are sourced from public releases. The maintainers make no representations about completeness or accuracy of the archive.
|
||||
2620
package-lock.json
generated
Normal file
2620
package-lock.json
generated
Normal file
File diff suppressed because it is too large
Load Diff
12
package.json
Normal file
12
package.json
Normal file
@ -0,0 +1,12 @@
|
||||
{
|
||||
"name": "document-explorer",
|
||||
"version": "1.0.0",
|
||||
"description": "Static site for exploring OCR'd documents",
|
||||
"scripts": {
|
||||
"build": "eleventy",
|
||||
"start": "eleventy --serve"
|
||||
},
|
||||
"devDependencies": {
|
||||
"@11ty/eleventy": "^2.0.1"
|
||||
}
|
||||
}
|
||||
314
process_images.py
Normal file
314
process_images.py
Normal file
@ -0,0 +1,314 @@
|
||||
#!/usr/bin/env python3
|
||||
"""
|
||||
Image processing script for OCR and entity extraction using OpenAI-compatible API.
|
||||
Processes images from Downloads folder and extracts structured data.
|
||||
"""
|
||||
|
||||
import os
|
||||
import json
|
||||
import base64
|
||||
from pathlib import Path
|
||||
from typing import Dict, List, Optional
|
||||
import concurrent.futures
|
||||
from dataclasses import dataclass, asdict
|
||||
from openai import OpenAI
|
||||
from tqdm import tqdm
|
||||
import argparse
|
||||
from dotenv import load_dotenv
|
||||
|
||||
|
||||
@dataclass
|
||||
class ProcessingResult:
|
||||
"""Structure for processing results"""
|
||||
filename: str
|
||||
success: bool
|
||||
data: Optional[Dict] = None
|
||||
error: Optional[str] = None
|
||||
|
||||
|
||||
class ImageProcessor:
|
||||
"""Process images using OpenAI-compatible vision API"""
|
||||
|
||||
def __init__(self, api_url: str, api_key: str, model: str = "gpt-4o", index_file: str = "processing_index.json", downloads_dir: Optional[str] = None):
|
||||
self.client = OpenAI(api_key=api_key, base_url=api_url)
|
||||
self.model = model
|
||||
self.downloads_dir = Path(downloads_dir) if downloads_dir else Path.home() / "Downloads"
|
||||
self.index_file = index_file
|
||||
self.processed_files = self.load_index()
|
||||
|
||||
def load_index(self) -> set:
|
||||
"""Load the index of already processed files"""
|
||||
if os.path.exists(self.index_file):
|
||||
try:
|
||||
with open(self.index_file, 'r') as f:
|
||||
data = json.load(f)
|
||||
return set(data.get('processed_files', []))
|
||||
except Exception as e:
|
||||
print(f"⚠️ Warning: Could not load index file: {e}")
|
||||
return set()
|
||||
return set()
|
||||
|
||||
def save_index(self):
|
||||
"""Save the current index of processed files"""
|
||||
with open(self.index_file, 'w') as f:
|
||||
json.dump({
|
||||
'processed_files': sorted(list(self.processed_files)),
|
||||
'last_updated': str(Path.cwd())
|
||||
}, f, indent=2)
|
||||
|
||||
def mark_processed(self, filename: str):
|
||||
"""Mark a file as processed and update index"""
|
||||
self.processed_files.add(filename)
|
||||
self.save_index()
|
||||
|
||||
def get_image_files(self) -> List[Path]:
|
||||
"""Get all image files from Downloads folder (recursively)"""
|
||||
image_extensions = {'.jpg', '.jpeg', '.png', '.gif', '.bmp', '.tiff', '.webp'}
|
||||
image_files = []
|
||||
|
||||
for ext in image_extensions:
|
||||
image_files.extend(self.downloads_dir.glob(f'**/*{ext}'))
|
||||
image_files.extend(self.downloads_dir.glob(f'**/*{ext.upper()}'))
|
||||
|
||||
return sorted(image_files)
|
||||
|
||||
def get_relative_path(self, file_path: Path) -> str:
|
||||
"""Get relative path from downloads directory for unique indexing"""
|
||||
try:
|
||||
return str(file_path.relative_to(self.downloads_dir))
|
||||
except ValueError:
|
||||
# If file is not relative to downloads_dir, use full path
|
||||
return str(file_path)
|
||||
|
||||
def get_unprocessed_files(self) -> List[Path]:
|
||||
"""Get only files that haven't been processed yet"""
|
||||
all_files = self.get_image_files()
|
||||
unprocessed = [f for f in all_files if self.get_relative_path(f) not in self.processed_files]
|
||||
return unprocessed
|
||||
|
||||
def encode_image(self, image_path: Path) -> str:
|
||||
"""Encode image to base64"""
|
||||
with open(image_path, 'rb') as f:
|
||||
return base64.b64encode(f.read()).decode('utf-8')
|
||||
|
||||
def get_system_prompt(self) -> str:
|
||||
"""Get the system prompt for structured extraction"""
|
||||
return """You are an expert OCR and document analysis system.
|
||||
Extract ALL text from the image in READING ORDER to create a digital twin of the document.
|
||||
|
||||
IMPORTANT: Transcribe text exactly as it appears on the page, from top to bottom, left to right, including:
|
||||
- All printed text
|
||||
- All handwritten text (inline where it appears)
|
||||
- Stamps and annotations (inline where they appear)
|
||||
- Signatures (note location)
|
||||
|
||||
Preserve the natural reading flow. Mix printed and handwritten text together in the order they appear.
|
||||
|
||||
Return ONLY valid JSON in this exact structure:
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "string or null",
|
||||
"document_number": "string or null",
|
||||
"date": "string or null",
|
||||
"document_type": "string or null",
|
||||
"has_handwriting": true/false,
|
||||
"has_stamps": true/false
|
||||
},
|
||||
"full_text": "Complete text transcription in reading order. Include ALL text - printed, handwritten, stamps, etc. - exactly as it appears from top to bottom.",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed|handwritten|stamp|signature|other",
|
||||
"content": "text content",
|
||||
"position": "top|middle|bottom|header|footer|margin"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": ["list of person names"],
|
||||
"organizations": ["list of organizations"],
|
||||
"locations": ["list of locations"],
|
||||
"dates": ["list of dates found"],
|
||||
"reference_numbers": ["list of any reference/ID numbers"]
|
||||
},
|
||||
"additional_notes": "Any observations about document quality, redactions, damage, etc."
|
||||
}"""
|
||||
|
||||
def process_image(self, image_path: Path) -> ProcessingResult:
|
||||
"""Process a single image through the API"""
|
||||
try:
|
||||
# Encode image
|
||||
base64_image = self.encode_image(image_path)
|
||||
|
||||
# Make API call using OpenAI client
|
||||
response = self.client.chat.completions.create(
|
||||
model=self.model,
|
||||
messages=[
|
||||
{
|
||||
"role": "system",
|
||||
"content": self.get_system_prompt()
|
||||
},
|
||||
{
|
||||
"role": "user",
|
||||
"content": [
|
||||
{
|
||||
"type": "text",
|
||||
"text": "Extract all text and entities from this image. Return only valid JSON."
|
||||
},
|
||||
{
|
||||
"type": "image_url",
|
||||
"image_url": {
|
||||
"url": f"data:image/jpeg;base64,{base64_image}"
|
||||
}
|
||||
}
|
||||
]
|
||||
}
|
||||
],
|
||||
max_tokens=4096,
|
||||
temperature=0.1
|
||||
)
|
||||
|
||||
# Parse response
|
||||
content = response.choices[0].message.content
|
||||
|
||||
# Parse JSON from content (strip markdown if present)
|
||||
content = content.strip()
|
||||
if content.startswith('```json'):
|
||||
content = content[7:]
|
||||
if content.startswith('```'):
|
||||
content = content[3:]
|
||||
if content.endswith('```'):
|
||||
content = content[:-3]
|
||||
content = content.strip()
|
||||
|
||||
extracted_data = json.loads(content)
|
||||
|
||||
return ProcessingResult(
|
||||
filename=self.get_relative_path(image_path),
|
||||
success=True,
|
||||
data=extracted_data
|
||||
)
|
||||
|
||||
except Exception as e:
|
||||
return ProcessingResult(
|
||||
filename=self.get_relative_path(image_path),
|
||||
success=False,
|
||||
error=str(e)
|
||||
)
|
||||
|
||||
def process_all(self, max_workers: int = 5, limit: Optional[int] = None, resume: bool = True) -> List[ProcessingResult]:
|
||||
"""Process all images with parallel processing"""
|
||||
if resume:
|
||||
image_files = self.get_unprocessed_files()
|
||||
total_files = len(self.get_image_files())
|
||||
already_processed = len(self.processed_files)
|
||||
print(f"Found {total_files} total image files")
|
||||
print(f"Already processed: {already_processed}")
|
||||
print(f"Remaining to process: {len(image_files)}")
|
||||
else:
|
||||
image_files = self.get_image_files()
|
||||
print(f"Found {len(image_files)} image files to process")
|
||||
|
||||
if limit:
|
||||
image_files = image_files[:limit]
|
||||
print(f"Limited to {limit} files for this run")
|
||||
|
||||
if not image_files:
|
||||
print("No files to process!")
|
||||
return []
|
||||
|
||||
results = []
|
||||
with concurrent.futures.ThreadPoolExecutor(max_workers=max_workers) as executor:
|
||||
futures = {executor.submit(self.process_image, img): img for img in image_files}
|
||||
|
||||
with tqdm(total=len(image_files), desc="Processing images") as pbar:
|
||||
for future in concurrent.futures.as_completed(futures):
|
||||
result = future.result()
|
||||
results.append(result)
|
||||
|
||||
# Save individual result to file
|
||||
if result.success:
|
||||
self.save_individual_result(result)
|
||||
|
||||
# Mark as processed regardless of success/failure
|
||||
self.mark_processed(result.filename)
|
||||
|
||||
pbar.update(1)
|
||||
|
||||
if not result.success:
|
||||
tqdm.write(f"❌ Failed: {result.filename} - {result.error}")
|
||||
else:
|
||||
tqdm.write(f"✅ Processed: {result.filename}")
|
||||
|
||||
return results
|
||||
|
||||
def save_individual_result(self, result: ProcessingResult):
|
||||
"""Save individual result to ./results/folder/imagename.json"""
|
||||
# Create output path mirroring the source structure
|
||||
result_path = Path("./results") / result.filename
|
||||
result_path = result_path.with_suffix('.json')
|
||||
|
||||
# Create parent directories
|
||||
result_path.parent.mkdir(parents=True, exist_ok=True)
|
||||
|
||||
# Save the extracted data
|
||||
with open(result_path, 'w', encoding='utf-8') as f:
|
||||
json.dump(result.data, f, indent=2, ensure_ascii=False)
|
||||
|
||||
def save_results(self, results: List[ProcessingResult], output_file: str = "processed_results.json"):
|
||||
"""Save summary results to JSON file"""
|
||||
output_data = {
|
||||
"total_processed": len(results),
|
||||
"successful": sum(1 for r in results if r.success),
|
||||
"failed": sum(1 for r in results if not r.success),
|
||||
"results": [asdict(r) for r in results]
|
||||
}
|
||||
|
||||
with open(output_file, 'w', encoding='utf-8') as f:
|
||||
json.dump(output_data, f, indent=2, ensure_ascii=False)
|
||||
|
||||
print(f"\n✅ Summary saved to {output_file}")
|
||||
print(f" Individual results saved to ./results/")
|
||||
print(f" Successful: {output_data['successful']}")
|
||||
print(f" Failed: {output_data['failed']}")
|
||||
|
||||
|
||||
def main():
|
||||
# Load environment variables
|
||||
load_dotenv()
|
||||
|
||||
parser = argparse.ArgumentParser(description="Process images with OCR and entity extraction")
|
||||
parser.add_argument("--api-url", help="OpenAI-compatible API base URL (default: from .env or OPENAI_API_URL)")
|
||||
parser.add_argument("--api-key", help="API key (default: from .env or OPENAI_API_KEY)")
|
||||
parser.add_argument("--model", help="Model name (default: from .env, OPENAI_MODEL, or meta-llama/Llama-4-Maverick-17B-128E-Instruct)")
|
||||
parser.add_argument("--workers", type=int, default=5, help="Number of parallel workers (default: 5)")
|
||||
parser.add_argument("--limit", type=int, help="Limit number of images to process (for testing)")
|
||||
parser.add_argument("--output", default="processed_results.json", help="Output JSON file")
|
||||
parser.add_argument("--index", default="processing_index.json", help="Index file to track processed files")
|
||||
parser.add_argument("--downloads-dir", default="./downloads", help="Directory containing images (default: ./downloads)")
|
||||
parser.add_argument("--no-resume", action="store_true", help="Process all files, ignoring index")
|
||||
|
||||
args = parser.parse_args()
|
||||
|
||||
# Get values from args or environment variables
|
||||
api_url = args.api_url or os.getenv("OPENAI_API_URL", "http://...")
|
||||
api_key = args.api_key or os.getenv("OPENAI_API_KEY", "abcd1234")
|
||||
model = args.model or os.getenv("OPENAI_MODEL", "meta-llama/Llama-4-Maverick-17B-128E-Instruct")
|
||||
|
||||
processor = ImageProcessor(
|
||||
api_url=api_url,
|
||||
api_key=api_key,
|
||||
model=model,
|
||||
index_file=args.index,
|
||||
downloads_dir=args.downloads_dir
|
||||
)
|
||||
|
||||
results = processor.process_all(
|
||||
max_workers=args.workers,
|
||||
limit=args.limit,
|
||||
resume=not args.no_resume
|
||||
)
|
||||
|
||||
processor.save_results(results, args.output)
|
||||
|
||||
|
||||
if __name__ == "__main__":
|
||||
main()
|
||||
4311
processing_index.json
Normal file
4311
processing_index.json
Normal file
File diff suppressed because it is too large
Load Diff
3
requirements.txt
Normal file
3
requirements.txt
Normal file
@ -0,0 +1,3 @@
|
||||
openai
|
||||
tqdm
|
||||
python-dotenv
|
||||
89
results/IMAGES001/DOJ-OGR-00000002.json
Normal file
89
results/IMAGES001/DOJ-OGR-00000002.json
Normal file
@ -0,0 +1,89 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "1",
|
||||
"document_number": "109-1",
|
||||
"date": "09/17/2024",
|
||||
"document_type": "Court Document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page1 of 26\n22-1426-cr\nUnited States v. Maxwell\n\nIn the\nUnited States Court of Appeals\nfor the Second Circuit\n\nAUGUST TERM 2023\n\nNo. 22-1426-cr\n\nUNITED STATES OF AMERICA,\nAppellee,\nv.\nGHISLAINE MAXWELL, also known as Sealed Defendant 1,\nDefendant-Appellant.\n\nOn Appeal from the United States District Court for the Southern District of New York\n\nARGUED: MARCH 12, 2024\nDECIDED: SEPTEMBER 17, 2024\n\nBefore: CABRANES, WESLEY, and LOHIER, Circuit Judges.\n\nDOJ-OGR-00000002",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page1 of 26",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "22-1426-cr\nUnited States v. Maxwell",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "In the\nUnited States Court of Appeals\nfor the Second Circuit",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "AUGUST TERM 2023",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "No. 22-1426-cr",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "UNITED STATES OF AMERICA,\nAppellee,\nv.\nGHISLAINE MAXWELL, also known as Sealed Defendant 1,\nDefendant-Appellant.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "On Appeal from the United States District Court for the Southern District of New York",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "ARGUED: MARCH 12, 2024\nDECIDED: SEPTEMBER 17, 2024",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Before: CABRANES, WESLEY, and LOHIER, Circuit Judges.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000002",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"GHISLAINE MAXWELL",
|
||||
"CABRANES",
|
||||
"WESLEY",
|
||||
"LOHIER"
|
||||
],
|
||||
"organizations": [
|
||||
"United States Court of Appeals",
|
||||
"United States District Court"
|
||||
],
|
||||
"locations": [
|
||||
"New York"
|
||||
],
|
||||
"dates": [
|
||||
"MARCH 12, 2024",
|
||||
"SEPTEMBER 17, 2024"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426-cr",
|
||||
"109-1",
|
||||
"3634097",
|
||||
"DOJ-OGR-00000002"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing from the United States Court of Appeals for the Second Circuit. It is the first page of a 26-page document."
|
||||
}
|
||||
76
results/IMAGES001/DOJ-OGR-00000003.json
Normal file
76
results/IMAGES001/DOJ-OGR-00000003.json
Normal file
@ -0,0 +1,76 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "2",
|
||||
"document_number": "109-1",
|
||||
"date": "09/17/2024",
|
||||
"document_type": "Court Document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page2 of 26\n\nDefendant Ghislaine Maxwell appeals her June 29, 2022, judgment of conviction in the United States District Court for the Southern District of New York (Alison J. Nathan, Judge). Maxwell was convicted of conspiracy to transport minors with intent to engage in criminal sexual activity in violation of 18 U.S.C. § 371; transportation of a minor with intent to engage in criminal sexual activity in violation of 18 U.S.C. § 2423(a); and sex trafficking of a minor in violation of 18 U.S.C. § 1591(a) and (b)(2). She was principally sentenced to concurrent terms of imprisonment of 60 months, 120 months, and 240 months, respectively, to be followed by concurrent terms of supervised release.\n\nOn appeal, the questions presented are whether (1) Jeffrey Epstein's Non-Prosecution Agreement with the United States Attorney's Office for the Southern District of Florida barred Maxwell's prosecution by the United States Attorney's Office for the Southern District of New York; (2) a second superseding indictment of March 29, 2021, complied with the statute of limitations; (3) the District Court abused its discretion in denying Maxwell's Rule 33 motion for a new trial based on the claimed violation of her Sixth Amendment right to a fair and impartial jury; (4) the District Court's response to a jury note resulted in a constructive amendment of, or prejudicial variance from, the allegations in the second superseding indictment; and (5) Maxwell's sentence was procedurally reasonable.\n\nIdentifying no errors in the District Court's conduct of this complex case, we AFFIRM the District Court's June 29, 2022, judgment of conviction.\n\n2\nDOJ-OGR-00000003",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page2 of 26",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Defendant Ghislaine Maxwell appeals her June 29, 2022, judgment of conviction in the United States District Court for the Southern District of New York (Alison J. Nathan, Judge). Maxwell was convicted of conspiracy to transport minors with intent to engage in criminal sexual activity in violation of 18 U.S.C. § 371; transportation of a minor with intent to engage in criminal sexual activity in violation of 18 U.S.C. § 2423(a); and sex trafficking of a minor in violation of 18 U.S.C. § 1591(a) and (b)(2). She was principally sentenced to concurrent terms of imprisonment of 60 months, 120 months, and 240 months, respectively, to be followed by concurrent terms of supervised release.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "On appeal, the questions presented are whether (1) Jeffrey Epstein's Non-Prosecution Agreement with the United States Attorney's Office for the Southern District of Florida barred Maxwell's prosecution by the United States Attorney's Office for the Southern District of New York; (2) a second superseding indictment of March 29, 2021, complied with the statute of limitations; (3) the District Court abused its discretion in denying Maxwell's Rule 33 motion for a new trial based on the claimed violation of her Sixth Amendment right to a fair and impartial jury; (4) the District Court's response to a jury note resulted in a constructive amendment of, or prejudicial variance from, the allegations in the second superseding indictment; and (5) Maxwell's sentence was procedurally reasonable.",
|
||||
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|
||||
},
|
||||
{
|
||||
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|
||||
"content": "Identifying no errors in the District Court's conduct of this complex case, we AFFIRM the District Court's June 29, 2022, judgment of conviction.",
|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"entities": {
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
"dates": [
|
||||
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|
||||
"March 29, 2021",
|
||||
"09/17/2024"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426",
|
||||
"109-1",
|
||||
"3634097",
|
||||
"18 U.S.C. § 371",
|
||||
"18 U.S.C. § 2423(a)",
|
||||
"18 U.S.C. § 1591(a)",
|
||||
"18 U.S.C. § (b)(2)",
|
||||
"DOJ-OGR-00000003"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court document related to Ghislaine Maxwell's appeal. The text is clear and legible, with no visible redactions or damage."
|
||||
}
|
||||
78
results/IMAGES001/DOJ-OGR-00000004.json
Normal file
78
results/IMAGES001/DOJ-OGR-00000004.json
Normal file
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|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "3",
|
||||
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||||
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|
||||
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|
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|
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|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page3 of 26\n\nANDREW ROHRBACH, Assistant United States Attorney (Maurene Comey, Alison Moe, Lara Pomerantz, Won S. Shin, Assistant United States Attorneys, on the brief), for Damian Williams, United States Attorney for the Southern District of New York, New York, NY, for Appellee.\n\nDIANA FABI SAMSON (Arthur L. Aidala, John M. Leventhal, on the brief), Aidala Bertuna & Kamins PC, New York, NY, for Defendant-Appellant.\n\nJOSÉ A. CABRANES, Circuit Judge:\n\nDefendant Ghislaine Maxwell appeals her June 29, 2022, judgment of conviction in the United States District Court for the Southern District of New York (Alison J. Nathan, Judge). Maxwell was convicted of conspiracy to transport minors with intent to engage in criminal sexual activity in violation of 18 U.S.C. § 371; transportation of a minor with intent to engage in criminal sexual activity in violation of 18 U.S.C. § 2423(a); and sex trafficking of a minor in violation of 18 U.S.C. § 1591(a) and (b)(2). The District Court imposed concurrent terms of imprisonment of 60 months, 120 months, and 240 months, respectively, to be followed by concurrent terms of supervised release\n\n3\nDOJ-OGR-00000004",
|
||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Defendant Ghislaine Maxwell appeals her June 29, 2022, judgment of conviction in the United States District Court for the Southern District of New York (Alison J. Nathan, Judge). Maxwell was convicted of conspiracy to transport minors with intent to engage in criminal sexual activity in violation of 18 U.S.C. § 371; transportation of a minor with intent to engage in criminal sexual activity in violation of 18 U.S.C. § 2423(a); and sex trafficking of a minor in violation of 18 U.S.C. § 1591(a) and (b)(2). The District Court imposed concurrent terms of imprisonment of 60 months, 120 months, and 240 months, respectively, to be followed by concurrent terms of supervised release",
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||||
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||||
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||||
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||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
"Diana Fabi Samson",
|
||||
"Arthur L. Aidala",
|
||||
"John M. Leventhal",
|
||||
"José A. Cabranes",
|
||||
"Ghislaine Maxwell",
|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"additional_notes": "The document appears to be a court document, specifically a page from a legal brief or opinion. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and easy to read."
|
||||
}
|
||||
65
results/IMAGES001/DOJ-OGR-00000005.json
Normal file
65
results/IMAGES001/DOJ-OGR-00000005.json
Normal file
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|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "4",
|
||||
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||||
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|
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"full_text": "of three years, three years, and five years, respectively. The District Court also imposed a fine of $250,000 on each count for a total of $750,000.\n\nOn appeal, the questions presented are (1) whether Jeffrey Epstein's Non-Prosecution Agreement (\"NPA\") with the United States Attorney's Office for the Southern District of Florida (\"USAO-SDFL\") barred Maxwell's prosecution by the United States Attorney's Office for the Southern District of New York (\"USAO-SDNY\"); (2) whether Maxwell's second superseding indictment of March 29, 2021 (the \"Indictment\") complied with the statute of limitations; (3) whether the District Court abused its discretion in denying Maxwell's Rule 33 motion for a new trial based on the claimed violation of her Sixth Amendment right to a fair and impartial jury; (4) whether the District Court's response to a jury note resulted in a constructive amendment of, or prejudicial variance from, the allegations in the Indictment; and (5) whether Maxwell's sentence was procedurally reasonable.\n\nWe hold that Epstein's NPA did not bar Maxwell's prosecution by USAO-SDNY as the NPA does not bind USAO-SDNY. We hold that Maxwell's Indictment complied with the statute of limitations as 18 U.S.C. § 3283 extended the time to bring charges of sexual abuse for offenses committed before the date of the statute's enactment. We further hold that the District Court did not abuse its discretion in denying Maxwell's Rule 33 motion for a new trial based on one juror's erroneous answers during voir dire. We also hold that the District Court's response to a jury note did not result in a constructive amendment of, or prejudicial variance from, the allegations in the",
|
||||
"text_blocks": [
|
||||
{
|
||||
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||||
"content": "of three years, three years, and five years, respectively. The District Court also imposed a fine of $250,000 on each count for a total of $750,000.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "On appeal, the questions presented are (1) whether Jeffrey Epstein's Non-Prosecution Agreement (\"NPA\") with the United States Attorney's Office for the Southern District of Florida (\"USAO-SDFL\") barred Maxwell's prosecution by the United States Attorney's Office for the Southern District of New York (\"USAO-SDNY\"); (2) whether Maxwell's second superseding indictment of March 29, 2021 (the \"Indictment\") complied with the statute of limitations; (3) whether the District Court abused its discretion in denying Maxwell's Rule 33 motion for a new trial based on the claimed violation of her Sixth Amendment right to a fair and impartial jury; (4) whether the District Court's response to a jury note resulted in a constructive amendment of, or prejudicial variance from, the allegations in the Indictment; and (5) whether Maxwell's sentence was procedurally reasonable.",
|
||||
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|
||||
},
|
||||
{
|
||||
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|
||||
"content": "We hold that Epstein's NPA did not bar Maxwell's prosecution by USAO-SDNY as the NPA does not bind USAO-SDNY. We hold that Maxwell's Indictment complied with the statute of limitations as 18 U.S.C. § 3283 extended the time to bring charges of sexual abuse for offenses committed before the date of the statute's enactment. We further hold that the District Court did not abuse its discretion in denying Maxwell's Rule 33 motion for a new trial based on one juror's erroneous answers during voir dire. We also hold that the District Court's response to a jury note did not result in a constructive amendment of, or prejudicial variance from, the allegations in the",
|
||||
"position": "middle"
|
||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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||||
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|
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"United States Attorney's Office for the Southern District of Florida",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"22-1426",
|
||||
"109-1",
|
||||
"3634097",
|
||||
"DOJ-OGR-00000005",
|
||||
"18 U.S.C. § 3283"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court document related to the case of Maxwell, with references to legal statutes and proceedings. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
|
||||
}
|
||||
75
results/IMAGES001/DOJ-OGR-00000006.json
Normal file
75
results/IMAGES001/DOJ-OGR-00000006.json
Normal file
@ -0,0 +1,75 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "5",
|
||||
"document_number": "109-1",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page5 of 26\n\nIndictment. Lastly, we hold that Maxwell's sentence is procedurally reasonable.\n\nAccordingly, we AFFIRM the District Court's June 29, 2022, judgment of conviction.\n\nI. BACKGROUND 1\n\nDefendant Ghislaine Maxwell coordinated, facilitated, and contributed to Jeffrey Epstein's sexual abuse of women and underage girls. Starting in 1994, Maxwell groomed numerous young women to engage in sexual activity with Epstein by building friendships with these young women, gradually normalizing discussions of sexual topics and sexual abuse. Until about 2004, this pattern of sexual abuse continued as Maxwell provided Epstein access to underage girls in various locations in the United States.\n\n1. Epstein's Non-Prosecution Agreement\n\nIn September 2007, following state and federal investigations into allegations of Epstein's unlawful sexual activity, Epstein entered into an NPA with USAO-SDFL. In the NPA, Epstein agreed to plead guilty to one count of solicitation of prostitution, in violation of Florida law.\n\n1 Unless otherwise noted, the following facts are drawn from the evidence presented at trial and described in the light most favorable to the Government. See United States v. Litwok, 678 F.3d 208, 210-11 (2d Cir. 2012) (\"Because this is an appeal from a judgment of conviction entered after a jury trial, the [ ] facts are drawn from the trial evidence and described in the light most favorable to the Government.\")\n\n5\n\nDOJ-OGR-00000006",
|
||||
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||||
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||||
},
|
||||
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|
||||
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|
||||
"content": "Indictment. Lastly, we hold that Maxwell's sentence is procedurally reasonable.\n\nAccordingly, we AFFIRM the District Court's June 29, 2022, judgment of conviction.",
|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "I. BACKGROUND 1\n\nDefendant Ghislaine Maxwell coordinated, facilitated, and contributed to Jeffrey Epstein's sexual abuse of women and underage girls. Starting in 1994, Maxwell groomed numerous young women to engage in sexual activity with Epstein by building friendships with these young women, gradually normalizing discussions of sexual topics and sexual abuse. Until about 2004, this pattern of sexual abuse continued as Maxwell provided Epstein access to underage girls in various locations in the United States.",
|
||||
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|
||||
},
|
||||
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|
||||
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|
||||
"content": "1. Epstein's Non-Prosecution Agreement\n\nIn September 2007, following state and federal investigations into allegations of Epstein's unlawful sexual activity, Epstein entered into an NPA with USAO-SDFL. In the NPA, Epstein agreed to plead guilty to one count of solicitation of prostitution, in violation of Florida law.",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"content": "1 Unless otherwise noted, the following facts are drawn from the evidence presented at trial and described in the light most favorable to the Government. See United States v. Litwok, 678 F.3d 208, 210-11 (2d Cir. 2012) (\"Because this is an appeal from a judgment of conviction entered after a jury trial, the [ ] facts are drawn from the trial evidence and described in the light most favorable to the Government.\")",
|
||||
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|
||||
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||||
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||||
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||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"District Court",
|
||||
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|
||||
],
|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
"dates": [
|
||||
"June 29, 2022",
|
||||
"1994",
|
||||
"2004",
|
||||
"September 2007"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426",
|
||||
"109-1",
|
||||
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|
||||
"678 F.3d 208"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court document related to the case of Ghislaine Maxwell. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and easy to read."
|
||||
}
|
||||
91
results/IMAGES001/DOJ-OGR-00000007.json
Normal file
91
results/IMAGES001/DOJ-OGR-00000007.json
Normal file
@ -0,0 +1,91 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "6",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page6 of 26\n\nStatutes § 796.07,2 and to one count of solicitation of minors to engage in prostitution, in violation of Florida Statutes § 796.03.3 He agreed to receive a sentence of eighteen months' imprisonment on the two charges. In consideration of Epstein's agreement, the NPA states that \"the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova.\"4\n\n2. Maxwell's Indictment and Trial-Related Proceedings\n\nThe Indictment filed against Maxwell contained eight counts, six of which proceeded to trial.5 Prior to the commencement of trial,\n\n2 Florida Statutes § 796.07 provides in relevant part:\n\n(2) It is unlawful:\n\n(f) To solicit, induce, entice, or procure another to commit prostitution, lewdness, or assignation.\n\n3 Florida Statutes § 796.03, which has since been repealed, provided in relevant part: \"A person who procures for prostitution, or causes to be prostituted, any person who is under the age of 18 years commits a felony of the second degree.\"\n\n4 A-178.\n\n5 Count One charged Maxwell with conspiracy to entice minors to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 371. Count Two charged Maxwell with enticement of a minor to travel to engage in illegal sex acts, in violation of 18 U.S.C. §§ 2422 and 2. Count Three charged Maxwell with conspiracy to transport minors with intent to engage in criminal sexual activity, in violation of 18 U.S.C. § 371. Count Four charged Maxwell with transportation of a minor with intent to engage in criminal sexual activity, in violation of 18 U.S.C. §§ 2423(a) and 2. Count Five charged Maxwell with sex trafficking conspiracy, in",
|
||||
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||||
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|
||||
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||||
},
|
||||
{
|
||||
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|
||||
"content": "Statutes § 796.07,2 and to one count of solicitation of minors to engage in prostitution, in violation of Florida Statutes § 796.03.3 He agreed to receive a sentence of eighteen months' imprisonment on the two charges. In consideration of Epstein's agreement, the NPA states that \"the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova.\"4",
|
||||
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|
||||
},
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"type": "printed",
|
||||
"content": "The Indictment filed against Maxwell contained eight counts, six of which proceeded to trial.5 Prior to the commencement of trial,",
|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "2 Florida Statutes § 796.07 provides in relevant part:\n\n(2) It is unlawful:\n\n(f) To solicit, induce, entice, or procure another to commit prostitution, lewdness, or assignation.",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "3 Florida Statutes § 796.03, which has since been repealed, provided in relevant part: \"A person who procures for prostitution, or causes to be prostituted, any person who is under the age of 18 years commits a felony of the second degree.\"",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "4 A-178.",
|
||||
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|
||||
},
|
||||
{
|
||||
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|
||||
"content": "5 Count One charged Maxwell with conspiracy to entice minors to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 371. Count Two charged Maxwell with enticement of a minor to travel to engage in illegal sex acts, in violation of 18 U.S.C. §§ 2422 and 2. Count Three charged Maxwell with conspiracy to transport minors with intent to engage in criminal sexual activity, in violation of 18 U.S.C. § 371. Count Four charged Maxwell with transportation of a minor with intent to engage in criminal sexual activity, in violation of 18 U.S.C. §§ 2423(a) and 2. Count Five charged Maxwell with sex trafficking conspiracy, in",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
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|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-0000007",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Epstein",
|
||||
"Sarah Kellen",
|
||||
"Adriana Ross",
|
||||
"Lesley Groff",
|
||||
"Nadia Marcinkova",
|
||||
"Maxwell"
|
||||
],
|
||||
"organizations": [
|
||||
"United States"
|
||||
],
|
||||
"locations": [],
|
||||
"dates": [
|
||||
"09/17/2024"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426",
|
||||
"109-1",
|
||||
"3634097",
|
||||
"A-178",
|
||||
"18 U.S.C. § 371",
|
||||
"18 U.S.C. §§ 2422 and 2",
|
||||
"18 U.S.C. § 371",
|
||||
"18 U.S.C. §§ 2423(a) and 2"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a legal document related to the case of Maxwell, discussing the indictment and trial proceedings. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and clear to read."
|
||||
}
|
||||
91
results/IMAGES001/DOJ-OGR-00000008.json
Normal file
91
results/IMAGES001/DOJ-OGR-00000008.json
Normal file
@ -0,0 +1,91 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page7 of 26\n\nprospective jurors completed a lengthy questionnaire, with several questions raising issues relevant to the trial. Based on the completed questionnaires, the parties selected prospective jurors to proceed to in-person voir dire. The District Court ultimately empaneled a jury.\n\nDuring the four-and-a-half-week jury trial, the Government presented evidence of the repeated sexual abuse of six girls. At the conclusion of trial, on December 29, 2021, the jury found Maxwell guilty on all but one count.6\n\nFollowing the verdict, Juror 50 gave press interviews during which he stated that he was a survivor of child sexual abuse.7 In his answers to the written jury questionnaire, however, Juror 50 answered \"no\" to three questions asking whether he or a friend or family member had ever been the victim of a crime; whether he or a friend or family member had ever been the victim of sexual harassment, sexual abuse, or sexual assault; and whether he or a friend or family member had ever been accused of sexual harassment, sexual abuse, or sexual assault.\n\nviolation of 18 U.S.C. § 371. Count Six charged Maxwell with sex trafficking of a minor, in violation of 18 U.S.C. §§ 1591(a), (b)(2), and 2. Counts Seven and Eight charged Maxwell with perjury, in violation of 18 U.S.C. § 1623. The perjury charges were severed from the remaining charges and ultimately dismissed at sentencing.\n\n6 The jury found Maxwell guilty on Counts One, Three, Four, Five, and Six. Maxwell was acquitted on Count Two.\n\n7 Consistent with a juror anonymity order entered for trial, the parties and the District Court referred to the jurors by pseudonym.\n\n7\nDOJ-OGR-00000008",
|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "prospective jurors completed a lengthy questionnaire, with several questions raising issues relevant to the trial. Based on the completed questionnaires, the parties selected prospective jurors to proceed to in-person voir dire. The District Court ultimately empaneled a jury.",
|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "During the four-and-a-half-week jury trial, the Government presented evidence of the repeated sexual abuse of six girls. At the conclusion of trial, on December 29, 2021, the jury found Maxwell guilty on all but one count.6",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Following the verdict, Juror 50 gave press interviews during which he stated that he was a survivor of child sexual abuse.7 In his answers to the written jury questionnaire, however, Juror 50 answered \"no\" to three questions asking whether he or a friend or family member had ever been the victim of a crime; whether he or a friend or family member had ever been the victim of sexual harassment, sexual abuse, or sexual assault; and whether he or a friend or family member had ever been accused of sexual harassment, sexual abuse, or sexual assault.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "violation of 18 U.S.C. § 371. Count Six charged Maxwell with sex trafficking of a minor, in violation of 18 U.S.C. §§ 1591(a), (b)(2), and 2. Counts Seven and Eight charged Maxwell with perjury, in violation of 18 U.S.C. § 1623. The perjury charges were severed from the remaining charges and ultimately dismissed at sentencing.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "6 The jury found Maxwell guilty on Counts One, Three, Four, Five, and Six. Maxwell was acquitted on Count Two.",
|
||||
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|
||||
},
|
||||
{
|
||||
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|
||||
"content": "7 Consistent with a juror anonymity order entered for trial, the parties and the District Court referred to the jurors by pseudonym.",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"dates": [
|
||||
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|
||||
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|
||||
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|
||||
"reference_numbers": [
|
||||
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|
||||
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|
||||
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|
||||
"18 U.S.C. § 371",
|
||||
"18 U.S.C. §§ 1591(a), (b)(2), and 2",
|
||||
"18 U.S.C. § 1623",
|
||||
"Count One",
|
||||
"Count Two",
|
||||
"Count Three",
|
||||
"Count Four",
|
||||
"Count Five",
|
||||
"Count Six",
|
||||
"Count Seven",
|
||||
"Count Eight",
|
||||
"DOJ-OGR-00000008"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court document related to the trial of Maxwell. The text is mostly printed, with some footnotes and a header. There are no visible stamps or handwritten text."
|
||||
}
|
||||
68
results/IMAGES001/DOJ-OGR-00000009.json
Normal file
68
results/IMAGES001/DOJ-OGR-00000009.json
Normal file
@ -0,0 +1,68 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "8",
|
||||
"document_number": "109-1",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page8 of 26 assault.8 Upon learning of the interviews, the Government filed a letter on January 5, 2022, requesting a hearing; Maxwell then moved for a new trial under Federal Rule of Criminal Procedure 33. On March 8, 2022, the District Court held a hearing and Juror 50 testified —under grant of immunity—that his answers to three questions related to sexual abuse in the jury questionnaire were not accurate but that the answers were an inadvertent mistake and that his experiences did not affect his ability to be fair and impartial. Finding Juror 50's testimony to be credible, the District Court denied Maxwell's motion for a new trial in a written order. Maxwell was subsequently sentenced to a term of 240 months' imprisonment to be followed by five years' supervised release, and the 8 Question 2 asked \"[h]ave you, or any of your relatives or close friends, ever been a victim of a crime?\" Question 48 asked \"[h]ave you or a friend or family member ever been the victim of sexual harassment, sexual abuse, or sexual assault? (This includes actual or attempted sexual assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher, or family member.)\" Finally, Question 49 asked [h]ave you or a friend or family member ever been accused of sexual harassment, sexual abuse, or sexual assault? (This includes both formal accusations in a court of law or informal accusations in a social or work setting of actual or attempted sexual assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher, or family member. See A-299, A-310. 8 DOJ-OGR-0000009",
|
||||
"text_blocks": [
|
||||
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|
||||
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|
||||
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|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "assault.8 Upon learning of the interviews, the Government filed a letter on January 5, 2022, requesting a hearing; Maxwell then moved for a new trial under Federal Rule of Criminal Procedure 33. On March 8, 2022, the District Court held a hearing and Juror 50 testified —under grant of immunity—that his answers to three questions related to sexual abuse in the jury questionnaire were not accurate but that the answers were an inadvertent mistake and that his experiences did not affect his ability to be fair and impartial. Finding Juror 50's testimony to be credible, the District Court denied Maxwell's motion for a new trial in a written order. Maxwell was subsequently sentenced to a term of 240 months' imprisonment to be followed by five years' supervised release, and the",
|
||||
"position": "main content"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "8 Question 2 asked \"[h]ave you, or any of your relatives or close friends, ever been a victim of a crime?\" Question 48 asked \"[h]ave you or a friend or family member ever been the victim of sexual harassment, sexual abuse, or sexual assault? (This includes actual or attempted sexual assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher, or family member.)\" Finally, Question 49 asked [h]ave you or a friend or family member ever been accused of sexual harassment, sexual abuse, or sexual assault? (This includes both formal accusations in a court of law or informal accusations in a social or work setting of actual or attempted sexual assault or other unwanted sexual advance, including by a stranger, acquaintance, supervisor, teacher, or family member.",
|
||||
"position": "footnote"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "See A-299, A-310.",
|
||||
"position": "footnote"
|
||||
},
|
||||
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|
||||
"type": "printed",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"content": "DOJ-OGR-0000009",
|
||||
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|
||||
}
|
||||
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|
||||
"entities": {
|
||||
"people": [
|
||||
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|
||||
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|
||||
],
|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
"locations": [],
|
||||
"dates": [
|
||||
"January 5, 2022",
|
||||
"March 8, 2022",
|
||||
"09/17/2024"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426",
|
||||
"109-1",
|
||||
"3634097",
|
||||
"A-299",
|
||||
"A-310",
|
||||
"DOJ-OGR-0000009"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court document related to the case of Maxwell. It includes details about the trial, the testimony of Juror 50, and the sentencing of Maxwell. The document is well-formatted and free of significant damage or redactions."
|
||||
}
|
||||
92
results/IMAGES001/DOJ-OGR-00000010.json
Normal file
92
results/IMAGES001/DOJ-OGR-00000010.json
Normal file
@ -0,0 +1,92 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "9",
|
||||
"document_number": "109-1",
|
||||
"date": "09/17/2024",
|
||||
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|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page9 of 26\nDistrict Court imposed a $750,000 fine and a $300 mandatory special assessment. This appeal followed.\nII. DISCUSSION\n1. The NPA Between Epstein and USAO-SDFL Did Not Bar Maxwell's Prosecution by USAO-SDNY\nMaxwell sought dismissal of the charges in the Indictment on the grounds that the NPA made between Epstein and USAO-SDFL immunized her from prosecution on all counts as a third-party beneficiary of the NPA. The District Court denied the motion, rejecting Maxwell's arguments. We agree. We review de novo the denial of a motion to dismiss an indictment.9\nIn arguing that the NPA barred her prosecution by USAO-SDNY, Maxwell cites the portion of the NPA in which \"the United States [ ] agree[d] that it w[ould] not institute any criminal charges against any potential co-conspirators of Epstein.\"10 We hold that the NPA with USAO-SDFL does not bind USAO-SDNY.\nIt is well established in our Circuit that \"[a] plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement\n9 See, e.g., United States v. Walters, 910 F.3d 11, 22 (2d Cir. 2018).\n10 A-178.\n9\nDOJ-OGR-00000010",
|
||||
"text_blocks": [
|
||||
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|
||||
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|
||||
"content": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page9 of 26",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "District Court imposed a $750,000 fine and a $300 mandatory special assessment. This appeal followed.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "II. DISCUSSION",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "1. The NPA Between Epstein and USAO-SDFL Did Not Bar Maxwell's Prosecution by USAO-SDNY",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Maxwell sought dismissal of the charges in the Indictment on the grounds that the NPA made between Epstein and USAO-SDFL immunized her from prosecution on all counts as a third-party beneficiary of the NPA. The District Court denied the motion, rejecting Maxwell's arguments. We agree. We review de novo the denial of a motion to dismiss an indictment.9",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "In arguing that the NPA barred her prosecution by USAO-SDNY, Maxwell cites the portion of the NPA in which \"the United States [ ] agree[d] that it w[ould] not institute any criminal charges against any potential co-conspirators of Epstein.\"10 We hold that the NPA with USAO-SDFL does not bind USAO-SDNY.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "It is well established in our Circuit that \"[a] plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "9 See, e.g., United States v. Walters, 910 F.3d 11, 22 (2d Cir. 2018).",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "10 A-178.",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "9",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000010",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Maxwell",
|
||||
"Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"District Court",
|
||||
"USAO-SDFL",
|
||||
"USAO-SDNY",
|
||||
"United States Attorney"
|
||||
],
|
||||
"locations": [],
|
||||
"dates": [
|
||||
"09/17/2024"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426",
|
||||
"109-1",
|
||||
"3634097",
|
||||
"910 F.3d 11",
|
||||
"A-178"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court document related to the case of Maxwell, discussing the NPA between Epstein and USAO-SDFL and its implications for Maxwell's prosecution by USAO-SDNY. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and clear."
|
||||
}
|
||||
69
results/IMAGES001/DOJ-OGR-00000011.json
Normal file
69
results/IMAGES001/DOJ-OGR-00000011.json
Normal file
@ -0,0 +1,69 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "10",
|
||||
"document_number": "109-1",
|
||||
"date": "09/17/2024",
|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page10 of 26\n\ncontemplates a broader restriction.\"11 And while Maxwell contends that we cannot apply Annabi to an agreement negotiated and executed outside of this Circuit, we have previously done just that.12 Applying Annabi, we conclude that the NPA did not bar Maxwell's prosecution by USAO-SDNY. There is nothing in the NPA that affirmatively shows that the NPA was intended to bind multiple districts. Instead, where the NPA is not silent, the agreement's scope is expressly limited to the Southern District of Florida. The NPA makes clear that if Epstein fulfilled his obligations, he would no longer face charges in that district:\n\nAfter timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any\n\n11 United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985). We recognize that circuits have been split on this issue for decades. See United States v. Harvey, 791 F.2d 294, 303 (4th Cir. 1986); United States v. Gebbie, 294 F.3d 540, 550 (3d Cir. 2002).\n\n12 See, e.g., United States v. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) (summary order) (applying Annabi to plea agreement entered into in the District of New Jersey); United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004) (summary order) (same, to agreement entered into in the District of New Mexico). Nor does Annabi, as Maxwell contends, apply only where subsequent charges are \"sufficiently distinct\" from charges covered by an earlier agreement. In Annabi, this Court rejected an interpretation of a prior plea agreement that rested on the Double Jeopardy Clause, reasoning that even if the Double Jeopardy Clause applied, the subsequent charges were \"sufficiently distinct\" and therefore fell outside the Clause's protections. Annabi, 771 F.2d at 672. This Court did not, however, conclude that the rule of construction it announced depended on the similarities between earlier and subsequent charges.\n\n10\nDOJ-OGR-00000011",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page10 of 26",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "contemplates a broader restriction.\"11 And while Maxwell contends that we cannot apply Annabi to an agreement negotiated and executed outside of this Circuit, we have previously done just that.12 Applying Annabi, we conclude that the NPA did not bar Maxwell's prosecution by USAO-SDNY. There is nothing in the NPA that affirmatively shows that the NPA was intended to bind multiple districts. Instead, where the NPA is not silent, the agreement's scope is expressly limited to the Southern District of Florida. The NPA makes clear that if Epstein fulfilled his obligations, he would no longer face charges in that district:\n\nAfter timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any",
|
||||
"position": "main body"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "11 United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985). We recognize that circuits have been split on this issue for decades. See United States v. Harvey, 791 F.2d 294, 303 (4th Cir. 1986); United States v. Gebbie, 294 F.3d 540, 550 (3d Cir. 2002).\n\n12 See, e.g., United States v. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) (summary order) (applying Annabi to plea agreement entered into in the District of New Jersey); United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004) (summary order) (same, to agreement entered into in the District of New Mexico). Nor does Annabi, as Maxwell contends, apply only where subsequent charges are \"sufficiently distinct\" from charges covered by an earlier agreement. In Annabi, this Court rejected an interpretation of a prior plea agreement that rested on the Double Jeopardy Clause, reasoning that even if the Double Jeopardy Clause applied, the subsequent charges were \"sufficiently distinct\" and therefore fell outside the Clause's protections. Annabi, 771 F.2d at 672. This Court did not, however, conclude that the rule of construction it announced depended on the similarities between earlier and subsequent charges.",
|
||||
"position": "footnote"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "10",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
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|
||||
"content": "DOJ-OGR-00000011",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Maxwell",
|
||||
"Epstein",
|
||||
"Annabi",
|
||||
"Harvey",
|
||||
"Gebbie",
|
||||
"Prisco",
|
||||
"Gonzalez"
|
||||
],
|
||||
"organizations": [
|
||||
"USAO-SDNY",
|
||||
"Federal Bureau of Investigation",
|
||||
"United States Attorney's Office"
|
||||
],
|
||||
"locations": [
|
||||
"Southern District of Florida",
|
||||
"District of New Jersey",
|
||||
"District of New Mexico"
|
||||
],
|
||||
"dates": [
|
||||
"09/17/2024"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426",
|
||||
"109-1",
|
||||
"3634097",
|
||||
"DOJ-OGR-00000011"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Maxwell, discussing the applicability of a non-prosecution agreement (NPA) to her prosecution. The text includes citations to various court cases and references to specific legal concepts, such as the Double Jeopardy Clause."
|
||||
}
|
||||
95
results/IMAGES001/DOJ-OGR-00000012.json
Normal file
95
results/IMAGES001/DOJ-OGR-00000012.json
Normal file
@ -0,0 +1,95 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "11",
|
||||
"document_number": "109-1",
|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page11 of 26\noffenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed.13\nThe only language in the NPA that speaks to the agreement's scope is limiting language.\nThe negotiation history of the NPA, just as the text, fails to show that the agreement was intended to bind other districts. Under our Court's precedent, the negotiation history of an NPA can support an inference that an NPA \"affirmatively\" binds other districts.14 Yet, the actions of USAC-SDFL do not indicate that the NPA was intended to bind other districts.\nThe United States Attorney's Manual that was operable during the negotiations of the NPA required that:\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\n13 A-175 (emphasis added). The agreement's scope is also limited in an additional section:\nTHEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below.\nId. (emphasis added).\n14 See United States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986).\n11\nDOJ-OGR-00000012",
|
||||
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||||
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||||
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||||
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||||
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||||
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|
||||
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||||
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|
||||
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|
||||
},
|
||||
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|
||||
"type": "printed",
|
||||
"content": "The only language in the NPA that speaks to the agreement's scope is limiting language.",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"content": "The negotiation history of the NPA, just as the text, fails to show that the agreement was intended to bind other districts. Under our Court's precedent, the negotiation history of an NPA can support an inference that an NPA \"affirmatively\" binds other districts.14 Yet, the actions of USAC-SDFL do not indicate that the NPA was intended to bind other districts.",
|
||||
"position": "middle"
|
||||
},
|
||||
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|
||||
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|
||||
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||||
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|
||||
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||||
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|
||||
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||||
"content": "No 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",
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||||
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|
||||
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|
||||
{
|
||||
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|
||||
"content": "13 A-175 (emphasis added). The agreement's scope is also limited in an additional section:\nTHEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below.",
|
||||
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|
||||
},
|
||||
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|
||||
"type": "printed",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"type": "printed",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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||||
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|
||||
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||||
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|
||||
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||||
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|
||||
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||||
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|
||||
"entities": {
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"locations": [
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"reference_numbers": [
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court document related to the case of Epstein. The text is mostly printed, with some footnotes and citations. There are no visible stamps or handwritten text."
|
||||
}
|
||||
81
results/IMAGES001/DOJ-OGR-00000013.json
Normal file
81
results/IMAGES001/DOJ-OGR-00000013.json
Normal file
@ -0,0 +1,81 @@
|
||||
{
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||||
"document_metadata": {
|
||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page12 of 26\n\nthe United States Attorney(s) in each affected district and/or the Assistant Attorney General of the Criminal Division.15\n\nNothing before us indicates that USAO-SDNY had been notified or had approved of Epstein's NPA with USAO-SDFL and intended to be bound by it. And the Assistant Attorney General for the Criminal Division stated in an interview with the Office of Professional Responsibility that she \"played no role\" in the NPA, either by reviewing or approving the agreement.\n\nThe history of the Office of the United States Attorney is instructive as to the scope of their actions and duties. The Judiciary Act of 1789 created the Office of the United States Attorney, along with the office of the Attorney General. More specifically, the Judiciary Act provided for the appointment, in each district, of a \"person learned in the law to act as attorney for the United States in such district, who shall be sworn or affirmed to the faithful execution of his office, whose duty it shall be to prosecute in such district all delinquents for crimes and offences, cognizable under the authority of the United States, and all civil actions in which the United States shall be concerned.\"16 The Judiciary Act thus emphasized that U.S. Attorneys would enforce the law of the United States but did not determine that the actions of one U.S. Attorney could bind other districts, let alone the entire nation. In fact, the phrase \"in such district,\" repeated twice, implies that the scope of\n\n15 United States Attorney's Manual § 9-27.641 (2007).\n16 An Act to Establish the Judicial Courts of the United States, ch. 20, § 35, 1 Stat. 73, 92-93 (1789) (emphasis added).\n\n12\nDOJ-OGR-00000013",
|
||||
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||||
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||||
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|
||||
},
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Nothing before us indicates that USAO-SDNY had been notified or had approved of Epstein's NPA with USAO-SDFL and intended to be bound by it. And the Assistant Attorney General for the Criminal Division stated in an interview with the Office of Professional Responsibility that she \"played no role\" in the NPA, either by reviewing or approving the agreement.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "The history of the Office of the United States Attorney is instructive as to the scope of their actions and duties. The Judiciary Act of 1789 created the Office of the United States Attorney, along with the office of the Attorney General. More specifically, the Judiciary Act provided for the appointment, in each district, of a \"person learned in the law to act as attorney for the United States in such district, who shall be sworn or affirmed to the faithful execution of his office, whose duty it shall be to prosecute in such district all delinquents for crimes and offences, cognizable under the authority of the United States, and all civil actions in which the United States shall be concerned.\"16 The Judiciary Act thus emphasized that U.S. Attorneys would enforce the law of the United States but did not determine that the actions of one U.S. Attorney could bind other districts, let alone the entire nation. In fact, the phrase \"in such district,\" repeated twice, implies that the scope of",
|
||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
"type": "printed",
|
||||
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|
||||
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|
||||
},
|
||||
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|
||||
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|
||||
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||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
"entities": {
|
||||
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|
||||
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|
||||
],
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"DOJ-OGR-00000013"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a legal document related to a court case, with references to specific laws and regulations. The text is printed, with no handwritten content or stamps visible."
|
||||
}
|
||||
86
results/IMAGES001/DOJ-OGR-00000014.json
Normal file
86
results/IMAGES001/DOJ-OGR-00000014.json
Normal file
@ -0,0 +1,86 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "13",
|
||||
"document_number": "109-1",
|
||||
"date": "09/17/2024",
|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page13 of 26\n\nthe actions and the duties of the U.S. Attorneys would be limited to their own districts, absent any express exceptions.\n\nSince 1789, while the number of federal districts has grown significantly, the duties of a U.S. Attorney and their scope remain largely unchanged. By statute, U.S. Attorneys, \"within [their] district, shall (1) prosecute for all offenses against the United States; (2) prosecute or defend, for the Government, all civil actions, suits or proceedings in which the United States is concerned.\"17 Again, the scope of the duties of a U.S. Attorney is cabined to their specific district unless otherwise directed.18\n\nIn short, Annabi controls the result here. Nothing in the text of the NPA or its negotiation history suggests that the NPA precluded USAO-SDNY from prosecuting Maxwell for the charges in the\n\n17 28 U.S.C. § 547.\n18 This does not suggest that there are no instances in which a U.S. Attorney's powers do not extend beyond their districts. For instance, under 28 U.S.C. § 515 a U.S. Attorney can represent the Government or participate in proceedings in other districts, but only when specifically directed by the Attorney General:\n\nThe Attorney General or any other officer of the Department of Justice, or any attorney specially appointed by the Attorney General under law, may, when specifically directed by the Attorney General, conduct any kind of legal proceeding ... which United States attorneys are authorized by law to conduct, whether or not he is a resident of the district in which the proceeding is brought.\n\n13\nDOJ-OGR-00000014",
|
||||
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|
||||
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||||
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||||
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|
||||
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||||
},
|
||||
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||||
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|
||||
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|
||||
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|
||||
},
|
||||
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|
||||
"type": "printed",
|
||||
"content": "Since 1789, while the number of federal districts has grown significantly, the duties of a U.S. Attorney and their scope remain largely unchanged. By statute, U.S. Attorneys, \"within [their] district, shall (1) prosecute for all offenses against the United States; (2) prosecute or defend, for the Government, all civil actions, suits or proceedings in which the United States is concerned.\"17 Again, the scope of the duties of a U.S. Attorney is cabined to their specific district unless otherwise directed.18",
|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "In short, Annabi controls the result here. Nothing in the text of the NPA or its negotiation history suggests that the NPA precluded USAO-SDNY from prosecuting Maxwell for the charges in the",
|
||||
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|
||||
},
|
||||
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|
||||
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|
||||
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|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "18 This does not suggest that there are no instances in which a U.S. Attorney's powers do not extend beyond their districts. For instance, under 28 U.S.C. § 515 a U.S. Attorney can represent the Government or participate in proceedings in other districts, but only when specifically directed by the Attorney General:",
|
||||
"position": "footer"
|
||||
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|
||||
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|
||||
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|
||||
"content": "The Attorney General or any other officer of the Department of Justice, or any attorney specially appointed by the Attorney General under law, may, when specifically directed by the Attorney General, conduct any kind of legal proceeding ... which United States attorneys are authorized by law to conduct, whether or not he is a resident of the district in which the proceeding is brought.",
|
||||
"position": "bottom"
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
"dates": [
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a legal document, likely a court filing or brief, discussing the duties and scope of U.S. Attorneys. The text is printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
|
||||
}
|
||||
70
results/IMAGES001/DOJ-OGR-00000015.json
Normal file
70
results/IMAGES001/DOJ-OGR-00000015.json
Normal file
@ -0,0 +1,70 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "14",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page14 of 26\n\nIndictment. The District Court therefore correctly denied Maxwell's motion without an evidentiary hearing.\n\n2. The Indictment Is Timely\n\nMaxwell argues that Counts Three and Four of the Indictment are untimely because they do not fall within the scope of offenses involving the sexual or physical abuse or kidnapping of a minor and thereby do not fall within the extended statute of limitations provided by § 3283.19 Separately, Maxwell contends that the Government cannot apply the 2003 amendment to § 3283 that extended the statute of limitations to those offenses that were committed before the enactment into law of the provision. On both points, we disagree and hold that the District Court correctly denied Maxwell's motions to dismiss the charges as untimely. We review de novo the denial of a motion to dismiss an indictment and the application of a statute of limitations.20\n\nFirst, Counts Three and Four of the Indictment are offenses involving the sexual abuse of minors. The District Court properly applied Weingarten v. United States.21 In Weingarten, we explained that Congress intended courts to apply § 3283 using a case-specific\n\n19 18 U.S.C. § 3283 provides: \"[n]o statute of limitations that would otherwise preclude prosecution for an offense involving the sexual or physical abuse, or kidnaping, of a child under the age of 18 years shall preclude such prosecution during the life of the child, or for ten years after the offense, whichever is longer.\"\n\n20 United States v. Sampson, 898 F.3d 270, 276, 278 (2d Cir. 2018).\n\n21 865 F.3d 48, 58-60 (2d Cir. 2017); see also United States v. Maxwell, 534 F. Supp. 3d 299, 313-14 (S.D.N.Y. 2021).\n\n14\nDOJ-OGR-00000015",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page14 of 26",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Indictment. The District Court therefore correctly denied Maxwell's motion without an evidentiary hearing.\n\n2. The Indictment Is Timely\n\nMaxwell argues that Counts Three and Four of the Indictment are untimely because they do not fall within the scope of offenses involving the sexual or physical abuse or kidnapping of a minor and thereby do not fall within the extended statute of limitations provided by § 3283.19 Separately, Maxwell contends that the Government cannot apply the 2003 amendment to § 3283 that extended the statute of limitations to those offenses that were committed before the enactment into law of the provision. On both points, we disagree and hold that the District Court correctly denied Maxwell's motions to dismiss the charges as untimely. We review de novo the denial of a motion to dismiss an indictment and the application of a statute of limitations.20\n\nFirst, Counts Three and Four of the Indictment are offenses involving the sexual abuse of minors. The District Court properly applied Weingarten v. United States.21 In Weingarten, we explained that Congress intended courts to apply § 3283 using a case-specific",
|
||||
"position": "main content"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "19 18 U.S.C. § 3283 provides: \"[n]o statute of limitations that would otherwise preclude prosecution for an offense involving the sexual or physical abuse, or kidnaping, of a child under the age of 18 years shall preclude such prosecution during the life of the child, or for ten years after the offense, whichever is longer.\"\n\n20 United States v. Sampson, 898 F.3d 270, 276, 278 (2d Cir. 2018).\n\n21 865 F.3d 48, 58-60 (2d Cir. 2017); see also United States v. Maxwell, 534 F. Supp. 3d 299, 313-14 (S.D.N.Y. 2021).",
|
||||
"position": "footnote"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "14",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
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|
||||
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|
||||
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|
||||
}
|
||||
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|
||||
"entities": {
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"locations": [
|
||||
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|
||||
],
|
||||
"dates": [
|
||||
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|
||||
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|
||||
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|
||||
"2018",
|
||||
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|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426",
|
||||
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|
||||
"3634097",
|
||||
"§ 3283",
|
||||
"18 U.S.C. § 3283",
|
||||
"865 F.3d 48",
|
||||
"898 F.3d 270",
|
||||
"534 F. Supp. 3d 299",
|
||||
"DOJ-OGR-00000015"
|
||||
]
|
||||
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|
||||
"additional_notes": "The document appears to be a court document, specifically a page from a legal brief or opinion. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and the text is clear."
|
||||
}
|
||||
78
results/IMAGES001/DOJ-OGR-00000016.json
Normal file
78
results/IMAGES001/DOJ-OGR-00000016.json
Normal file
@ -0,0 +1,78 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "15",
|
||||
"document_number": "109-1",
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||||
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||||
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||||
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||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page15 of 26\n\napproach as opposed to a \"categorical approach.\"22 We see no reason to depart from our reasoning in Weingarten. Accordingly, the question presented here is whether the charged offenses involved the sexual abuse of a minor for the purposes of § 3283 based on the facts of the case. Jane, one of the women who testified at trial, gave evidence that she had been sexually abused when transported across state lines as a minor. Counts Three and Four thus qualify as offenses, and § 3283 applies to those offenses.\n\nSecond, Maxwell argues that Counts Three, Four, and Six of the Indictment are barred by the statute of limitations because the extended statute of limitations provided by the 2003 amendment to § 3283 does not apply to pre-enactment conduct. In Landgraf v. USI Film Products, the Supreme Court held that a court, in deciding whether a statute applies retroactively, must first \"determine whether Congress has expressly prescribed the statute's proper reach.\"23 If Congress has done so, \"the inquiry ends, and the court enforces the\n\n22 The \"categorical approach\" is a method of statutory interpretation that requires courts to look \"only to the statutory definitions of the prior offenses, and not to the particular facts underlying those convictions\" for sentencing and immigration purposes. Taylor v. United States, 495 U.S. 575, 600 (1990). We properly reasoned in Weingarten that § 3283 met none of the conditions listed by Taylor that might require application of the categorical approach. See Weingarten, 865 F.3d at 58-60. First, \"[t]he language of § 3283[] . . . reaches beyond the offense and its legal elements to the conduct 'involv[ed]' in the offense.\" Id. at 59-60. Second, legislative history suggests that Congress intended § 3283 to be applied broadly. Id. at 60. Third, a case-specific approach would not produce practical difficulties or potential unfairness. Id.\n\n23 511 U.S. 244, 280 (1994); see also Weingarten, 865 F.3d at 54-55.\n\n15\nDOJ-OGR-00000016",
|
||||
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|
||||
{
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||||
"content": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page15 of 26",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "approach as opposed to a \"categorical approach.\"22 We see no reason to depart from our reasoning in Weingarten. Accordingly, the question presented here is whether the charged offenses involved the sexual abuse of a minor for the purposes of § 3283 based on the facts of the case. Jane, one of the women who testified at trial, gave evidence that she had been sexually abused when transported across state lines as a minor. Counts Three and Four thus qualify as offenses, and § 3283 applies to those offenses.",
|
||||
"position": "main body"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Second, Maxwell argues that Counts Three, Four, and Six of the Indictment are barred by the statute of limitations because the extended statute of limitations provided by the 2003 amendment to § 3283 does not apply to pre-enactment conduct. In Landgraf v. USI Film Products, the Supreme Court held that a court, in deciding whether a statute applies retroactively, must first \"determine whether Congress has expressly prescribed the statute's proper reach.\"23 If Congress has done so, \"the inquiry ends, and the court enforces the",
|
||||
"position": "main body"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "22 The \"categorical approach\" is a method of statutory interpretation that requires courts to look \"only to the statutory definitions of the prior offenses, and not to the particular facts underlying those convictions\" for sentencing and immigration purposes. Taylor v. United States, 495 U.S. 575, 600 (1990). We properly reasoned in Weingarten that § 3283 met none of the conditions listed by Taylor that might require application of the categorical approach. See Weingarten, 865 F.3d at 58-60. First, \"[t]he language of § 3283[] . . . reaches beyond the offense and its legal elements to the conduct 'involv[ed]' in the offense.\" Id. at 59-60. Second, legislative history suggests that Congress intended § 3283 to be applied broadly. Id. at 60. Third, a case-specific approach would not produce practical difficulties or potential unfairness. Id.",
|
||||
"position": "footnote"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "23 511 U.S. 244, 280 (1994); see also Weingarten, 865 F.3d at 54-55.",
|
||||
"position": "footnote"
|
||||
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|
||||
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||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"entities": {
|
||||
"people": [
|
||||
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|
||||
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|
||||
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|
||||
"organizations": [
|
||||
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|
||||
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|
||||
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||||
"locations": [
|
||||
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|
||||
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|
||||
"dates": [
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426",
|
||||
"109-1",
|
||||
"3634097",
|
||||
"§ 3283",
|
||||
"511 U.S. 244",
|
||||
"495 U.S. 575",
|
||||
"865 F.3d",
|
||||
"DOJ-OGR-00000016"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court document, likely a legal brief or opinion, discussing the application of § 3283 to certain offenses. The text includes citations to legal precedents and references to specific court cases."
|
||||
}
|
||||
73
results/IMAGES001/DOJ-OGR-00000017.json
Normal file
73
results/IMAGES001/DOJ-OGR-00000017.json
Normal file
@ -0,0 +1,73 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "16",
|
||||
"document_number": "109-1",
|
||||
"date": "09/17/2024",
|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
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|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page16 of 26\n\nstatute as it is written.\"24 If the statute \"is ambiguous or contains no express command regarding retroactivity, a reviewing court must determine whether applying the statute to antecedent conduct would create presumptively impermissible retroactive effects.\"25\n\nHere, the inquiry is straightforward. In 2003, Congress amended § 3283 to provide: \"No statute of limitations that would otherwise preclude prosecution for an offense involving the sexual or physical abuse, or kidnaping, of a child under the age of 18 years shall preclude such prosecution during the life of the child.\"26 The text of § 3283—that no statute of limitations that would otherwise preclude prosecution of these offenses will apply—plainly requires that it prevent the application of any statute of limitations that would otherwise apply to past conduct.\n\nThe statutory text makes clear that Congress intended to extend the time to bring charges of sexual abuse for pre-enactment conduct as the prior statute of limitations was inadequate. This is enough to conclude that the PROTECT Act's amendment to § 3283 applies to Maxwell's conduct as charged in the Indictment.\n\n24 In re Enter. Mortg. Acceptance Co., LLC, Sec. Litig., 391 F.3d 401, 406 (2d Cir. 2004) (citing Landgraf, 511 U.S. at 280).\n25 Weingarten, 865 F.3d at 55 (citation and internal quotation marks omitted).\n26 PROTECT Act, Pub. L. No. 108-21, § 202, 117 Stat. 650, 660 (2003).\n\n16\nDOJ-OGR-00000017",
|
||||
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||||
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||||
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|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "statute as it is written.\"24 If the statute \"is ambiguous or contains no express command regarding retroactivity, a reviewing court must determine whether applying the statute to antecedent conduct would create presumptively impermissible retroactive effects.\"25",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Here, the inquiry is straightforward. In 2003, Congress amended § 3283 to provide: \"No statute of limitations that would otherwise preclude prosecution for an offense involving the sexual or physical abuse, or kidnaping, of a child under the age of 18 years shall preclude such prosecution during the life of the child.\"26 The text of § 3283—that no statute of limitations that would otherwise preclude prosecution of these offenses will apply—plainly requires that it prevent the application of any statute of limitations that would otherwise apply to past conduct.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "The statutory text makes clear that Congress intended to extend the time to bring charges of sexual abuse for pre-enactment conduct as the prior statute of limitations was inadequate. This is enough to conclude that the PROTECT Act's amendment to § 3283 applies to Maxwell's conduct as charged in the Indictment.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "24 In re Enter. Mortg. Acceptance Co., LLC, Sec. Litig., 391 F.3d 401, 406 (2d Cir. 2004) (citing Landgraf, 511 U.S. at 280).\n25 Weingarten, 865 F.3d at 55 (citation and internal quotation marks omitted).\n26 PROTECT Act, Pub. L. No. 108-21, § 202, 117 Stat. 650, 660 (2003).",
|
||||
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|
||||
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|
||||
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||||
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||||
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||||
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||||
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|
||||
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||||
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||||
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||||
"entities": {
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||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"117 Stat. 650",
|
||||
"660",
|
||||
"DOJ-OGR-00000017"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to a case involving Maxwell, discussing the application of the PROTECT Act to charges of sexual abuse. The text is well-formatted and clear, with citations to relevant case law and statutes."
|
||||
}
|
||||
78
results/IMAGES001/DOJ-OGR-00000018.json
Normal file
78
results/IMAGES001/DOJ-OGR-00000018.json
Normal file
@ -0,0 +1,78 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "17",
|
||||
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||||
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||||
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|
||||
"has_handwriting": false,
|
||||
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|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page17 of 26\n\n3. The District Court Did Not Abuse Its Discretion in Denying Maxwell's Motion for a New Trial\n\nMaxwell contends that she was deprived of her constitutional right to a fair and impartial jury because Juror 50 failed to accurately respond to several questions related to his history of sexual abuse as part of the jury questionnaire during jury selection. Following a special evidentiary hearing, the District Court denied Maxwell's motion for a new trial.\n\nWe review a District Court's denial of a motion for a new trial for abuse of discretion.27 We have been extremely reluctant to \"haul jurors in after they have reached a verdict in order to probe for potential instances of bias, misconduct or extraneous influences.\"28 While courts can \"vacate any judgment and grant a new trial if the interest of justice so requires,\" Fed. R. Crim. P. 33(a), they should do so \"sparingly\" and only in \"the most extraordinary circumstances.\"29 A district court \"has\n\n27 See Rivas v. Brattesani, 94 F.3d 802, 807 (2d Cir. 1996). \"[W]e are mindful that a judge has not abused her discretion simply because she has made a different decision than we would have made in the first instance.\" United States v. Ferguson, 246 F.3d 129, 133 (2d Cir. 2001). We have repeatedly explained that the term of art \"abuse of discretion\" includes errors of law, a clearly erroneous assessment of the evidence, or \"a decision that cannot be located within the range of permissible decisions.\" In re Sims, 534 F.3d 117, 132 (2d Cir. 2008) (citation and internal quotation marks omitted).\n\n28 United States v. Moon, 718 F.2d 1210, 1234 (2d Cir. 1983).\n\n29 Ferguson, 246 F.3d at 134.\n\n17\nDOJ-OGR-00000018",
|
||||
"text_blocks": [
|
||||
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|
||||
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|
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|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "3. The District Court Did Not Abuse Its Discretion in Denying Maxwell's Motion for a New Trial",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Maxwell contends that she was deprived of her constitutional right to a fair and impartial jury because Juror 50 failed to accurately respond to several questions related to his history of sexual abuse as part of the jury questionnaire during jury selection. Following a special evidentiary hearing, the District Court denied Maxwell's motion for a new trial.",
|
||||
"position": "body"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "We review a District Court's denial of a motion for a new trial for abuse of discretion.27 We have been extremely reluctant to \"haul jurors in after they have reached a verdict in order to probe for potential instances of bias, misconduct or extraneous influences.\"28 While courts can \"vacate any judgment and grant a new trial if the interest of justice so requires,\" Fed. R. Crim. P. 33(a), they should do so \"sparingly\" and only in \"the most extraordinary circumstances.\"29 A district court \"has",
|
||||
"position": "body"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "27 See Rivas v. Brattesani, 94 F.3d 802, 807 (2d Cir. 1996). \"[W]e are mindful that a judge has not abused her discretion simply because she has made a different decision than we would have made in the first instance.\" United States v. Ferguson, 246 F.3d 129, 133 (2d Cir. 2001). We have repeatedly explained that the term of art \"abuse of discretion\" includes errors of law, a clearly erroneous assessment of the evidence, or \"a decision that cannot be located within the range of permissible decisions.\" In re Sims, 534 F.3d 117, 132 (2d Cir. 2008) (citation and internal quotation marks omitted).",
|
||||
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|
||||
},
|
||||
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|
||||
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|
||||
"content": "28 United States v. Moon, 718 F.2d 1210, 1234 (2d Cir. 1983).",
|
||||
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|
||||
},
|
||||
{
|
||||
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|
||||
"content": "29 Ferguson, 246 F.3d at 134.",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to a case involving Maxwell. The text is mostly printed, with some footnotes and citations. There are no visible stamps or handwritten text."
|
||||
}
|
||||
60
results/IMAGES001/DOJ-OGR-00000019.json
Normal file
60
results/IMAGES001/DOJ-OGR-00000019.json
Normal file
@ -0,0 +1,60 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "18",
|
||||
"document_number": "109-1",
|
||||
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|
||||
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|
||||
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||||
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|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page18 of 26\n\nbroad discretion to decide Rule 33 motions based upon its evaluation of the proof produced” and is shown deference on appeal.30\n\nA Rule 33 motion based on a juror's alleged erroneous response during voir dire is governed by McDonough Power Equipment, Inc. v. Greenwood.31 Under McDonough, a party seeking a new trial “must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause.”32\n\nThe District Court applied the McDonough standard, found Juror 50's testimony credible, and determined that Juror 50's erroneous responses during voir dire were “not deliberately incorrect” and that “he would not have been struck for cause if he had provided accurate responses to the questionnaire.”33 In fact, as the District Court noted, Maxwell did not challenge the inclusion of other jurors who disclosed past experience with sexual abuse, assault, or harassment. This is\n\n30 United States v. Gambino, 59 F.3d 353, 364 (2d Cir. 1995) (citation and internal quotation marks omitted).\n\n31 464 U.S. 548 (1984).\n\n32 Id. at 556.\n\n33 A-340 (emphasis added). The Supreme Court reminds us that “[t]o invalidate the result of a [ ] trial because of a juror's mistaken, though honest response to a question, is to insist on something closer to perfection than our judicial system can be expected to give.” McDonough, 464 U.S. at 555.\n\n18\n\nDOJ-OGR-00000019",
|
||||
"text_blocks": [
|
||||
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|
||||
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||||
"content": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page18 of 26",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "broad discretion to decide Rule 33 motions based upon its evaluation of the proof produced” and is shown deference on appeal.30\n\nA Rule 33 motion based on a juror's alleged erroneous response during voir dire is governed by McDonough Power Equipment, Inc. v. Greenwood.31 Under McDonough, a party seeking a new trial “must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause.”32\n\nThe District Court applied the McDonough standard, found Juror 50's testimony credible, and determined that Juror 50's erroneous responses during voir dire were “not deliberately incorrect” and that “he would not have been struck for cause if he had provided accurate responses to the questionnaire.”33 In fact, as the District Court noted, Maxwell did not challenge the inclusion of other jurors who disclosed past experience with sexual abuse, assault, or harassment. This is",
|
||||
"position": "main body"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "30 United States v. Gambino, 59 F.3d 353, 364 (2d Cir. 1995) (citation and internal quotation marks omitted).\n\n31 464 U.S. 548 (1984).\n\n32 Id. at 556.\n\n33 A-340 (emphasis added). The Supreme Court reminds us that “[t]o invalidate the result of a [ ] trial because of a juror's mistaken, though honest response to a question, is to insist on something closer to perfection than our judicial system can be expected to give.” McDonough, 464 U.S. at 555.",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "18",
|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
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|
||||
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|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
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|
||||
],
|
||||
"organizations": [],
|
||||
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|
||||
"dates": [
|
||||
"09/17/2024",
|
||||
"1984",
|
||||
"1995"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426",
|
||||
"109-1",
|
||||
"3634097",
|
||||
"464 U.S. 548",
|
||||
"59 F.3d 353",
|
||||
"A-340",
|
||||
"DOJ-OGR-00000019"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to a case involving Maxwell. The text discusses the application of Rule 33 motions and the McDonough standard in the context of juror responses during voir dire. The document includes citations to relevant case law and statutory authority."
|
||||
}
|
||||
96
results/IMAGES001/DOJ-OGR-00000020.json
Normal file
96
results/IMAGES001/DOJ-OGR-00000020.json
Normal file
@ -0,0 +1,96 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "19",
|
||||
"document_number": "109-1",
|
||||
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|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
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|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page19 of 26\nenough; the District Court did not abuse its discretion in denying Maxwell's motion for a new trial.34\n4. The District Court's Response to a Jury Note Did Not Result in a Constructive Amendment of, or Prejudicial Variance from, the Allegations in the Indictment\nDuring jury deliberations, the jury sent the following jury note regarding Count Four of the Indictment:\nUnder Count Four (4), if the defendant aided in the transportation of Jane's return flight, but not the flight to New Mexico where/if the intent was for Jane to engage in sexual activity, can she be found guilty under the second element?35\nThe District Court determined that it would not respond to the note directly because it was difficult to \"parse factually and legally\" and instead referred the jury to the second element of Count Four.36\n34 Nor did the District Court err in questioning Juror 50 rather than allowing the parties to do so. In conducting a hearing on potential juror misconduct, \"[w]e leave it to the district court's discretion to decide the extent to which the parties may participate in questioning the witnesses, and whether to hold the hearing in camera.\" United States v. Ianniello, 866 F.2d 540, 544 (2d Cir. 1989). And while Maxwell contends that the District Court improperly limited questioning about Juror 50's role in deliberations, she both waived that argument below and fails to show here how any such questioning would not be foreclosed by Federal Rule of Evidence 606(b).\n35 A-238.\n36 A-207-221. The District Court's instruction on the second element of Count Four required the jury to find that \"Maxwell knowingly transported Jane in interstate commerce with the\n19\nDOJ-OGR-00000020",
|
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|
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||||
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"content": "Under Count Four (4), if the defendant aided in the transportation of Jane's return flight, but not the flight to New Mexico where/if the intent was for Jane to engage in sexual activity, can she be found guilty under the second element?35",
|
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|
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|
||||
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|
||||
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||||
"content": "The District Court determined that it would not respond to the note directly because it was difficult to \"parse factually and legally\" and instead referred the jury to the second element of Count Four.36",
|
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|
||||
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|
||||
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|
||||
"type": "printed",
|
||||
"content": "34 Nor did the District Court err in questioning Juror 50 rather than allowing the parties to do so. In conducting a hearing on potential juror misconduct, \"[w]e leave it to the district court's discretion to decide the extent to which the parties may participate in questioning the witnesses, and whether to hold the hearing in camera.\" United States v. Ianniello, 866 F.2d 540, 544 (2d Cir. 1989). And while Maxwell contends that the District Court improperly limited questioning about Juror 50's role in deliberations, she both waived that argument below and fails to show here how any such questioning would not be foreclosed by Federal Rule of Evidence 606(b).",
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|
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|
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|
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|
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|
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|
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"3634097",
|
||||
"866 F.2d 540",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
}
|
||||
77
results/IMAGES001/DOJ-OGR-00000021.json
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||||
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|
||||
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||||
"page_number": "20",
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"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page20 of 26\n\nMaxwell subsequently filed a letter seeking reconsideration of the District Court's response, claiming that this response resulted in a constructive amendment or prejudicial variance. The District Court declined to reconsider its response and denied Maxwell's motion.\n\nMaxwell appeals the District Court's denial and argues that the alleged constructive amendment is a per se violation of the Grand Jury Clause of the Fifth Amendment. Specifically, Maxwell argues that testimony about a witness's sexual abuse in New Mexico presented the jury with another basis for conviction, which is distinct from the charges in the Indictment. Similarly, Maxwell argues that this testimony resulted in a prejudicial variance from the Indictment. We disagree and affirm the District Court's denial.\n\nWe review the denial of a motion claiming constructive amendment or prejudicial variance de novo.37 To satisfy the Fifth Amendment's Grand Jury Clause, \"an indictment must contain the elements of the offense charged and fairly inform the defendant of the charge against which he must defend.\"38 We have explained that to prevail on a constructive amendment claim, a defendant must demonstrate that \"the terms of the indictment are in effect altered by the presentation of evidence and jury instructions which so modify the essential elements of the offense charged that there is a substantial intent that Jane engage in sexual activity for which any person can be charged with a criminal offense in violation of New York law.\" A-205.\n\n37 See United States v. Dove, 884 F.3d 138, 146, 149 (2d Cir. 2018).\n38 United States v. Khilupsky, 5 F.4th 279, 293 (2d Cir. 2021).\n\n20\nDOJ-OGR-00000021",
|
||||
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|
||||
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||||
},
|
||||
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|
||||
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||||
"content": "Maxwell subsequently filed a letter seeking reconsideration of the District Court's response, claiming that this response resulted in a constructive amendment or prejudicial variance. The District Court declined to reconsider its response and denied Maxwell's motion.",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"content": "Maxwell appeals the District Court's denial and argues that the alleged constructive amendment is a per se violation of the Grand Jury Clause of the Fifth Amendment. Specifically, Maxwell argues that testimony about a witness's sexual abuse in New Mexico presented the jury with another basis for conviction, which is distinct from the charges in the Indictment. Similarly, Maxwell argues that this testimony resulted in a prejudicial variance from the Indictment. We disagree and affirm the District Court's denial.",
|
||||
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|
||||
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|
||||
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|
||||
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||||
"content": "We review the denial of a motion claiming constructive amendment or prejudicial variance de novo.37 To satisfy the Fifth Amendment's Grand Jury Clause, \"an indictment must contain the elements of the offense charged and fairly inform the defendant of the charge against which he must defend.\"38 We have explained that to prevail on a constructive amendment claim, a defendant must demonstrate that \"the terms of the indictment are in effect altered by the presentation of evidence and jury instructions which so modify the essential elements of the offense charged that there is a substantial intent that Jane engage in sexual activity for which any person can be charged with a criminal offense in violation of New York law.\" A-205.",
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||||
"content": "37 See United States v. Dove, 884 F.3d 138, 146, 149 (2d Cir. 2018).\n38 United States v. Khilupsky, 5 F.4th 279, 293 (2d Cir. 2021).",
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||||
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|
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||||
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||||
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||||
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||||
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||||
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||||
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|
||||
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|
||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
"884 F.3d 138",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"additional_notes": "The document appears to be a court document, specifically a page from a legal brief or opinion. The text is printed and there are no visible stamps or handwritten annotations. The document is well-formatted and the text is clear."
|
||||
}
|
||||
62
results/IMAGES001/DOJ-OGR-00000022.json
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results/IMAGES001/DOJ-OGR-00000022.json
Normal file
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||||
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||||
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|
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"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page21 of 26\n\nlikelihood that the defendant may have been convicted of an offense other than that charged in the indictment.\"39 A constructive amendment requires reversal.40\n\nWe cannot conclude that a constructive amendment resulted from the evidence presented by the Government—namely, Jane's testimony—or that it can be implied from the jury note. We have permitted significant flexibility in proof as long as a defendant was \"given notice of the core of criminality to be proven at trial.\"41 In turn, \"[t]he core of criminality of an offense involves the essence of a crime, in general terms; the particulars of how a defendant effected the crime falls outside that purview.\"42\n\nWe agree with the District Court that the jury instructions, the evidence presented at trial, and the Government's summation captured the core of criminality. As the District Court noted, while the jury note was ambiguous in one sense, it was clear that it referred to the second element of Count Four of the Indictment. Therefore, the District Court correctly directed the jury to that instruction, which \"accurately instructed that Count Four had to be predicated on finding\n\n39 United States v. Mollica, 849 F.2d 723, 729 (2d Cir. 1988).\n40 See United States v. D'Amelio, 683 F.3d 412, 417 (2d Cir. 2012).\n41 United States v. Ionia Mgmt. S.A., 555 F.3d 303, 310 (2d Cir. 2009) (per curiam) (emphasis omitted).\n42 D'Amelio, 683 F.3d at 418 (internal quotation marks omitted).\n\n21\nDOJ-OGR-00000022",
|
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|
||||
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||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "likelihood that the defendant may have been convicted of an offense other than that charged in the indictment.\"39 A constructive amendment requires reversal.40\n\nWe cannot conclude that a constructive amendment resulted from the evidence presented by the Government—namely, Jane's testimony—or that it can be implied from the jury note. We have permitted significant flexibility in proof as long as a defendant was \"given notice of the core of criminality to be proven at trial.\"41 In turn, \"[t]he core of criminality of an offense involves the essence of a crime, in general terms; the particulars of how a defendant effected the crime falls outside that purview.\"42\n\nWe agree with the District Court that the jury instructions, the evidence presented at trial, and the Government's summation captured the core of criminality. As the District Court noted, while the jury note was ambiguous in one sense, it was clear that it referred to the second element of Count Four of the Indictment. Therefore, the District Court correctly directed the jury to that instruction, which \"accurately instructed that Count Four had to be predicated on finding",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"content": "39 United States v. Mollica, 849 F.2d 723, 729 (2d Cir. 1988).\n40 See United States v. D'Amelio, 683 F.3d 412, 417 (2d Cir. 2012).\n41 United States v. Ionia Mgmt. S.A., 555 F.3d 303, 310 (2d Cir. 2009) (per curiam) (emphasis omitted).\n42 D'Amelio, 683 F.3d at 418 (internal quotation marks omitted).",
|
||||
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||||
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||||
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||||
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||||
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||||
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||||
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||||
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||||
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||||
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||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"additional_notes": "The document appears to be a court document, likely an appeal case, discussing the concept of constructive amendment and its implications on a defendant's conviction. The text includes citations to various court cases and legal precedents."
|
||||
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|
||||
59
results/IMAGES001/DOJ-OGR-00000023.json
Normal file
59
results/IMAGES001/DOJ-OGR-00000023.json
Normal file
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||||
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||||
"document_metadata": {
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||||
"page_number": "22",
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||||
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"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page22 of 26\na violation of New York law.\"43 It is therefore not \"uncertain whether [Maxwell] was convicted of conduct that was the subject of the grand jury's indictment.\"44\n\nWe also cannot conclude that the evidence at trial prejudicially varied from the Indictment. To allege a variance, a defendant \"must establish that the evidence offered at trial differs materially from the evidence alleged in the indictment.\"45 To prevail and win reversal, the defendant must further show \"that substantial prejudice occurred at trial as a result\" of the variance.46 \"A defendant cannot demonstrate that he has been prejudiced by a variance where the pleading and the proof substantially correspond, where the variance is not of a character that could have misled the defendant at the trial, and where the variance is not such as to deprive the accused of his right to be protected against another prosecution for the same offense.\"47\n\nFor reasons similar to the ones noted above in the context of the constructive amendment, the evidence at trial did not prove facts\n\n43 A-387; see United States v. Parker, 903 F.2d 91, 101 (2d Cir. 1990) (\"The trial judge is in the best position to sense whether the jury is able to proceed properly with its deliberations, and [] has considerable discretion in determining how to respond to communications indicating that the jury is experiencing confusion.)\n\n44 United States v. Salmonese, 352 F.3d 608, 620 (2d Cir. 2003).\n\n45 Dove, 884 F.3d at 149\n\n46 Id. (citation and internal quotation marks omitted).\n\n47 Salmonese, 352 F.3d at 621-22 (citation and internal quotation marks omitted); see also Khalupsky, 5 F.4th at 294.\n\n22\nDOJ-OGR-00000023",
|
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"content": "a violation of New York law.\"43 It is therefore not \"uncertain whether [Maxwell] was convicted of conduct that was the subject of the grand jury's indictment.\"44\n\nWe also cannot conclude that the evidence at trial prejudicially varied from the Indictment. To allege a variance, a defendant \"must establish that the evidence offered at trial differs materially from the evidence alleged in the indictment.\"45 To prevail and win reversal, the defendant must further show \"that substantial prejudice occurred at trial as a result\" of the variance.46 \"A defendant cannot demonstrate that he has been prejudiced by a variance where the pleading and the proof substantially correspond, where the variance is not of a character that could have misled the defendant at the trial, and where the variance is not such as to deprive the accused of his right to be protected against another prosecution for the same offense.\"47\n\nFor reasons similar to the ones noted above in the context of the constructive amendment, the evidence at trial did not prove facts",
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||||
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|
||||
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||||
"content": "43 A-387; see United States v. Parker, 903 F.2d 91, 101 (2d Cir. 1990) (\"The trial judge is in the best position to sense whether the jury is able to proceed properly with its deliberations, and [] has considerable discretion in determining how to respond to communications indicating that the jury is experiencing confusion.)\n\n44 United States v. Salmonese, 352 F.3d 608, 620 (2d Cir. 2003).\n\n45 Dove, 884 F.3d at 149\n\n46 Id. (citation and internal quotation marks omitted).\n\n47 Salmonese, 352 F.3d at 621-22 (citation and internal quotation marks omitted); see also Khalupsky, 5 F.4th at 294.",
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||||
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||||
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||||
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||||
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||||
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||||
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|
||||
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||||
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||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"additional_notes": "The document appears to be a court document, likely an appeal case, discussing legal precedents and the specifics of a trial involving Maxwell. The text includes citations to various legal cases and statutes."
|
||||
}
|
||||
90
results/IMAGES001/DOJ-OGR-00000024.json
Normal file
90
results/IMAGES001/DOJ-OGR-00000024.json
Normal file
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|
||||
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|
||||
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|
||||
"page_number": "23",
|
||||
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|
||||
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||||
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|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page23 of 26\n\n\"materially different\" from the allegations in the Indictment.48 The evidence indicated that Maxwell transported Jane to New York for sexual abuse and conspired to do the same. Maxwell knew that the evidence also included conduct in New Mexico.49 Furthermore, Maxwell cannot demonstrate \"substantial prejudice.\" Maxwell received—over three weeks before trial—notes of Jane's interview recording the abuse she suffered in New Mexico. This is enough to conclude that Maxwell was not \"unfairly and substantially\" prejudiced.50\n\n5. Maxwell's Sentence Was Procedurally Reasonable\n\nLastly, Maxwell argues that her sentence was procedurally unreasonable because the District Court erred in applying a leadership sentencing enhancement under the Sentencing Guidelines and inadequately explained its above-Guidelines sentence.51 We disagree.\n\n48 Dove, 884 F.3d at 149.\n\n49 As the District Court found, \"[t]he Indictment charged a scheme to sexually abuse underage girls in New York. In service of this scheme, the Indictment alleged that Epstein and the Defendant groomed the victims for abuse at various properties and in various states, including Epstein's ranch in New Mexico.\" A-393.\n\n50 See United States v. Lebedev, 932 F.3d 40, 54 (2d Cir. 2019) (concluding that a defendant was not \"unfairly and substantially\" prejudiced because \"[t]he government disclosed the evidence and exhibits . . . four weeks prior to trial\").\n\n51 At sentencing, the District Court calculated a Guidelines range of 188 to 235 months' imprisonment and sentenced Maxwell to a slightly above-Guidelines term of 240 months' imprisonment.\n\n23\nDOJ-OGR-00000024",
|
||||
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|
||||
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|
||||
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||||
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||||
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||||
"content": "\"materially different\" from the allegations in the Indictment.48 The evidence indicated that Maxwell transported Jane to New York for sexual abuse and conspired to do the same. Maxwell knew that the evidence also included conduct in New Mexico.49 Furthermore, Maxwell cannot demonstrate \"substantial prejudice.\" Maxwell received—over three weeks before trial—notes of Jane's interview recording the abuse she suffered in New Mexico. This is enough to conclude that Maxwell was not \"unfairly and substantially\" prejudiced.50",
|
||||
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|
||||
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|
||||
{
|
||||
"type": "printed",
|
||||
"content": "5. Maxwell's Sentence Was Procedurally Reasonable",
|
||||
"position": "main content"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Lastly, Maxwell argues that her sentence was procedurally unreasonable because the District Court erred in applying a leadership sentencing enhancement under the Sentencing Guidelines and inadequately explained its above-Guidelines sentence.51 We disagree.",
|
||||
"position": "main content"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "48 Dove, 884 F.3d at 149.",
|
||||
"position": "footnote"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "49 As the District Court found, \"[t]he Indictment charged a scheme to sexually abuse underage girls in New York. In service of this scheme, the Indictment alleged that Epstein and the Defendant groomed the victims for abuse at various properties and in various states, including Epstein's ranch in New Mexico.\" A-393.",
|
||||
"position": "footnote"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "50 See United States v. Lebedev, 932 F.3d 40, 54 (2d Cir. 2019) (concluding that a defendant was not \"unfairly and substantially\" prejudiced because \"[t]he government disclosed the evidence and exhibits . . . four weeks prior to trial\").",
|
||||
"position": "footnote"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "51 At sentencing, the District Court calculated a Guidelines range of 188 to 235 months' imprisonment and sentenced Maxwell to a slightly above-Guidelines term of 240 months' imprisonment.",
|
||||
"position": "footnote"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "23",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000024",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Maxwell",
|
||||
"Jane",
|
||||
"Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"District Court"
|
||||
],
|
||||
"locations": [
|
||||
"New York",
|
||||
"New Mexico"
|
||||
],
|
||||
"dates": [
|
||||
"09/17/2024"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426",
|
||||
"109-1",
|
||||
"3634097",
|
||||
"884 F.3d",
|
||||
"932 F.3d 40",
|
||||
"A-393",
|
||||
"DOJ-OGR-00000024"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Maxwell, discussing her sentence and allegations against her. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
|
||||
}
|
||||
71
results/IMAGES001/DOJ-OGR-00000025.json
Normal file
71
results/IMAGES001/DOJ-OGR-00000025.json
Normal file
@ -0,0 +1,71 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "24",
|
||||
"document_number": "109-1",
|
||||
"date": "09/17/2024",
|
||||
"document_type": "Court Document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page24 of 26\n\nWe review a sentence for both procedural and substantive reasonableness, which \"amounts to review for abuse of discretion.\"52 We have explained that procedural error is found when a district court \"fails to calculate (or improperly calculates) the Sentencing Guidelines range, treats the Sentencing Guidelines as mandatory, fails to consider the [Section] 3553(a) factors, selects a sentence based on clearly erroneous facts, or fails adequately to explain the chosen sentence.\"53 The District Court did none of that. It is important to emphasize that the Sentencing Guidelines \"are guidelines—that is, they are truly advisory.\"54 A District Court is \"generally free to impose sentences outside the recommended range\" based on its own \"informed and individualized judgment.\"55\n\nWith respect to the four-level leadership enhancement, the District Court found that Maxwell \"supervised\" Sarah Kellen in part because of testimony from two of Epstein's pilots who testified that Kellen was Maxwell's assistant. The District Court found that testimony credible, in part because it was corroborated by other testimony that Maxwell was Epstein's \"number two and the lady of the house\" in Palm Beach,\n\n52 United States v. Cavera, 550 F.3d 180, 187 (2d Cir. 2008) (en banc). \"Regardless of whether the sentence imposed is inside or outside the Guidelines range, the appellate court must review the sentence under an abuse-of-discretion standard.\" Gall v. United States, 552 U.S. 38, 51 (2007).\n\n53 United States v. Robinson, 702 F.3d 22, 38 (2d Cir. 2012).\n\n54 Cavera, 550 F.3d at 189.\n\n55 Id.\n\n24\nDOJ-OGR-00000025",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page24 of 26",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "We review a sentence for both procedural and substantive reasonableness, which \"amounts to review for abuse of discretion.\"52 We have explained that procedural error is found when a district court \"fails to calculate (or improperly calculates) the Sentencing Guidelines range, treats the Sentencing Guidelines as mandatory, fails to consider the [Section] 3553(a) factors, selects a sentence based on clearly erroneous facts, or fails adequately to explain the chosen sentence.\"53 The District Court did none of that. It is important to emphasize that the Sentencing Guidelines \"are guidelines—that is, they are truly advisory.\"54 A District Court is \"generally free to impose sentences outside the recommended range\" based on its own \"informed and individualized judgment.\"55",
|
||||
"position": "main content"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "With respect to the four-level leadership enhancement, the District Court found that Maxwell \"supervised\" Sarah Kellen in part because of testimony from two of Epstein's pilots who testified that Kellen was Maxwell's assistant. The District Court found that testimony credible, in part because it was corroborated by other testimony that Maxwell was Epstein's \"number two and the lady of the house\" in Palm Beach,",
|
||||
"position": "main content"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "52 United States v. Cavera, 550 F.3d 180, 187 (2d Cir. 2008) (en banc). \"Regardless of whether the sentence imposed is inside or outside the Guidelines range, the appellate court must review the sentence under an abuse-of-discretion standard.\" Gall v. United States, 552 U.S. 38, 51 (2007).\n\n53 United States v. Robinson, 702 F.3d 22, 38 (2d Cir. 2012).\n\n54 Cavera, 550 F.3d at 189.\n\n55 Id.",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "24",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000025",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Maxwell",
|
||||
"Sarah Kellen",
|
||||
"Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"District Court",
|
||||
"United States"
|
||||
],
|
||||
"locations": [
|
||||
"Palm Beach"
|
||||
],
|
||||
"dates": [
|
||||
"09/17/2024",
|
||||
"2007",
|
||||
"2012"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426",
|
||||
"109-1",
|
||||
"3634097",
|
||||
"550 F.3d 180",
|
||||
"552 U.S. 38",
|
||||
"702 F.3d 22"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court document related to a case involving Maxwell. The text is mostly printed, with no visible handwriting or stamps. The document includes citations to legal cases and references to specific court decisions."
|
||||
}
|
||||
72
results/IMAGES001/DOJ-OGR-00000026.json
Normal file
72
results/IMAGES001/DOJ-OGR-00000026.json
Normal file
@ -0,0 +1,72 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "25",
|
||||
"document_number": "109-1",
|
||||
"date": "09/17/2024",
|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page25 of 26\nwhere much of the abuse occurred and where Kellen worked.56 We therefore hold that the District Court did not err in applying the leadership enhancement.\nWith respect to the length of the sentence, the District Court properly discussed the sentencing factors when imposing the sentence, and described, at length, Maxwell's \"pivotal role in facilitating the abuse of the underaged girls through a series of deceptive tactics.\"57 The District Court recognized that the sentence \"must reflect the gravity of Ms. Maxwell's conduct, of Ms. Maxwell's offense, the pivotal role she played in facilitating the offense, and the significant and lasting harm it inflicted.\"58 And the District Court explained that \"a very serious, a very significant sentence is necessary to achieve the purposes of punishment\" under 18 U.S.C. § 3553(a). In sum, the District Court did not err by failing to adequately explain its sentence.\nCONCLUSION\nTo summarize, we hold as follows:\n56 A-417.\n57 SA-459.\n58 SA-461.\n25\nDOJ-OGR-00000026",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page25 of 26",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "where much of the abuse occurred and where Kellen worked.56 We therefore hold that the District Court did not err in applying the leadership enhancement.\nWith respect to the length of the sentence, the District Court properly discussed the sentencing factors when imposing the sentence, and described, at length, Maxwell's \"pivotal role in facilitating the abuse of the underaged girls through a series of deceptive tactics.\"57 The District Court recognized that the sentence \"must reflect the gravity of Ms. Maxwell's conduct, of Ms. Maxwell's offense, the pivotal role she played in facilitating the offense, and the significant and lasting harm it inflicted.\"58 And the District Court explained that \"a very serious, a very significant sentence is necessary to achieve the purposes of punishment\" under 18 U.S.C. § 3553(a). In sum, the District Court did not err by failing to adequately explain its sentence.",
|
||||
"position": "main body"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "CONCLUSION",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "To summarize, we hold as follows:",
|
||||
"position": "main body"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "56 A-417.\n57 SA-459.\n58 SA-461.",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "25",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000026",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Kellen",
|
||||
"Maxwell",
|
||||
"Ms. Maxwell"
|
||||
],
|
||||
"organizations": [
|
||||
"District Court"
|
||||
],
|
||||
"locations": [],
|
||||
"dates": [
|
||||
"09/17/2024"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426",
|
||||
"109-1",
|
||||
"3634097",
|
||||
"A-417",
|
||||
"SA-459",
|
||||
"SA-461",
|
||||
"DOJ-OGR-00000026"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court document, specifically a page from a legal brief or opinion. The text is well-formatted and printed, with no visible handwriting or stamps. The content discusses a court case involving Maxwell and the application of sentencing factors."
|
||||
}
|
||||
59
results/IMAGES001/DOJ-OGR-00000027.json
Normal file
59
results/IMAGES001/DOJ-OGR-00000027.json
Normal file
@ -0,0 +1,59 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "26",
|
||||
"document_number": "109-1",
|
||||
"date": "09/17/2024",
|
||||
"document_type": "Court Document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page26 of 26\n1. The District Court did not err in holding that Epstein's NPA with USAO-SDFL did not bar Maxwell's prosecution by USAO-SDNY.\n2. The District Court did not err in holding that the Indictment was filed within the statute of limitations.\n3. The District Court did not abuse its discretion in denying Maxwell's Rule 33 motion for a new trial.\n4. The District Court's response to a jury note did not result in a constructive amendment of, or prejudicial variance from, the allegations in the Indictment.\n5. The District Court's sentence was procedurally reasonable.\nFor the foregoing reasons, we AFFIRM the District Court's June 29, 2022, judgment of conviction.\n26\nDOJ-OGR-00000027",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page26 of 26",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "1. The District Court did not err in holding that Epstein's NPA with USAO-SDFL did not bar Maxwell's prosecution by USAO-SDNY.\n2. The District Court did not err in holding that the Indictment was filed within the statute of limitations.\n3. The District Court did not abuse its discretion in denying Maxwell's Rule 33 motion for a new trial.\n4. The District Court's response to a jury note did not result in a constructive amendment of, or prejudicial variance from, the allegations in the Indictment.\n5. The District Court's sentence was procedurally reasonable.\nFor the foregoing reasons, we AFFIRM the District Court's June 29, 2022, judgment of conviction.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "26",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000027",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Epstein",
|
||||
"Maxwell"
|
||||
],
|
||||
"organizations": [
|
||||
"USAO-SDFL",
|
||||
"USAO-SDNY",
|
||||
"District Court"
|
||||
],
|
||||
"locations": [
|
||||
"SDNY",
|
||||
"SDFL"
|
||||
],
|
||||
"dates": [
|
||||
"09/17/2024",
|
||||
"June 29, 2022"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426",
|
||||
"109-1",
|
||||
"3634097",
|
||||
"DOJ-OGR-00000027"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court ruling or judgment related to the case of Maxwell, with references to Epstein and various legal proceedings. The text is clear and legible, with no visible redactions or damage."
|
||||
}
|
||||
93
results/IMAGES001/DOJ-OGR-00000028.json
Normal file
93
results/IMAGES001/DOJ-OGR-00000028.json
Normal file
@ -0,0 +1,93 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "1",
|
||||
"document_number": "120",
|
||||
"date": "11/25/2024",
|
||||
"document_type": "Court Order",
|
||||
"has_handwriting": true,
|
||||
"has_stamps": true
|
||||
},
|
||||
"full_text": "Case 22-1426, Document 120, 11/25/2024, 3637560, Page1 of 1\n\nUNITED STATES COURT OF APPEALS\nFOR THE\nSECOND CIRCUIT\n\nAt a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 25th day of November, two thousand twenty-four.\n\nUnited States of America,\nAppellee,\nv.\nORDER\nGhislainc Maxwell, AKA Sealed Defendant 1,\nDocket No: 22-1426\nDefendant - Appellant.\n\nAppellant, Ghislaine Maxwell, filed a petition for panel rehearing, or, in the alternative, for rehearing en banc. The panel that determined the appeal has considered the request for panel rehearing, and the active members of the Court have considered the request for rehearing en banc.\n\nIT IS HEREBY ORDERED that the petition is denied.\n\nFOR THE COURT:\nCatherine O'Hagan Wolfe, Clerk\n\nCatherine O'Hagan Wolfe\nDOJ-OGR-00000028",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 22-1426, Document 120, 11/25/2024, 3637560, Page1 of 1",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "UNITED STATES COURT OF APPEALS\nFOR THE\nSECOND CIRCUIT",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 25th day of November, two thousand twenty-four.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "United States of America,\nAppellee,\nv.\nGhislainc Maxwell, AKA Sealed Defendant 1,\nDefendant - Appellant.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "ORDER\nDocket No: 22-1426",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Appellant, Ghislaine Maxwell, filed a petition for panel rehearing, or, in the alternative, for rehearing en banc. The panel that determined the appeal has considered the request for panel rehearing, and the active members of the Court have considered the request for rehearing en banc.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "IT IS HEREBY ORDERED that the petition is denied.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "FOR THE COURT:\nCatherine O'Hagan Wolfe, Clerk",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "Catherine O'Hagan Wolfe",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "stamp",
|
||||
"content": "",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000028",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Ghislaine Maxwell",
|
||||
"Catherine O'Hagan Wolfe"
|
||||
],
|
||||
"organizations": [
|
||||
"United States Court of Appeals",
|
||||
"United States Court of Appeals for the Second Circuit"
|
||||
],
|
||||
"locations": [
|
||||
"New York",
|
||||
"Thurgood Marshall United States Courthouse",
|
||||
"40 Foley Square"
|
||||
],
|
||||
"dates": [
|
||||
"November 25, 2024"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"22-1426",
|
||||
"120",
|
||||
"3637560",
|
||||
"DOJ-OGR-00000028"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document is a court order from the United States Court of Appeals for the Second Circuit. It appears to be a denial of a petition for rehearing filed by Ghislaine Maxwell. The document is signed by Catherine O'Hagan Wolfe, Clerk of the Court, and bears a stamp indicating it is an official document of the Second Circuit."
|
||||
}
|
||||
78
results/IMAGES001/DOJ-OGR-00000214.json
Normal file
78
results/IMAGES001/DOJ-OGR-00000214.json
Normal file
@ -0,0 +1,78 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": null,
|
||||
"document_number": "24-1073",
|
||||
"date": "May 9, 2025",
|
||||
"document_type": "Certificate of Compliance",
|
||||
"has_handwriting": true,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "SUPREME COURT OF THE UNITED STATES\nNo. 24-1073\n-------------------------------X\nGHISLAINE MAXWELL,\nPetitioner,\nv.\nUNITED STATES,\nRespondent.\n-------------------------------X\nCERTIFICATE OF COMPLIANCE\nAs required by Supreme Court Rule 33.1(h), I certify that the document contains 3,097 words, excluding the parts of the document that are exempted by Supreme Court Rule 33.1(d).\nI declare under penalty of perjury that the foregoing is true and correct.\nExecuted on this 9th day of May, 2025.\n\nRina Danielson\nSworn to and subscribed before me\nthis 9th day of May, 2025.\n\nMariana Braylovskiy\nMARIANA BRAYLOVSKIY\nNotary Public State of New York\nNo. 01BR6004935\nQualified in Richmond County\nCommission Expires March 30, 2026\n#120443",
|
||||
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||||
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|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "CERTIFICATE OF COMPLIANCE",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "As required by Supreme Court Rule 33.1(h), I certify that the document contains 3,097 words, excluding the parts of the document that are exempted by Supreme Court Rule 33.1(d).\nI declare under penalty of perjury that the foregoing is true and correct.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
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|
||||
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|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "Rina Danielson",
|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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||||
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|
||||
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||||
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|
||||
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|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
"organizations": [
|
||||
"Supreme Court of the United States",
|
||||
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|
||||
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||||
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|
||||
"New York",
|
||||
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|
||||
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|
||||
"dates": [
|
||||
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|
||||
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|
||||
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|
||||
"reference_numbers": [
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||||
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|
||||
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|
||||
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|
||||
]
|
||||
},
|
||||
"additional_notes": "The document is a Certificate of Compliance filed with the Supreme Court of the United States. It contains a notarized signature and is dated May 9, 2025."
|
||||
}
|
||||
94
results/IMAGES001/DOJ-OGR-00000215.json
Normal file
94
results/IMAGES001/DOJ-OGR-00000215.json
Normal file
@ -0,0 +1,94 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": null,
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||||
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||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
"full_text": "AFFIDAVIT OF SERVICE SUPREME COURT OF THE UNITED STATES No. 24-1073 GHISLAINE MAXWELL, Petitioner, v. UNITED STATES, Respondent. STATE OF NEW YORK ) COUNTY OF NEW YORK ) I, Rina Danielson, being duly sworn according to law and being over the age of 18, upon my oath depose and say that: I am retained by Counsel of Record for Amicus Curiae. That on the 9th day of May, 2025, I served the within Brief of Amicus Curiae National Association of Criminal Defense Lawyers in Support of Petitioner in the above-captioned matter upon: David Oscar Markus Markus/Moss Attorneys for Petitioner 40 N.W. Third Street Penthouse One Miami, FL 33128 (305) 379-6667 dmarkus@markuslaw.com D. John Sauer Solicitor General United States Department of Justice Attorneys for Respondent 950 Pennsylvania Avenue, N.W. Washington, DC 20530-0001 (202) 514-2217 SupremeCtBriefs@usdoj.gov by sending three copies of same, addressed to each individual respectively, and enclosed in a properly addressed wrapper, through the United States Postal DOJ-OGR-00000215",
|
||||
"text_blocks": [
|
||||
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|
||||
"type": "printed",
|
||||
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||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "SUPREME COURT OF THE UNITED STATES",
|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "No. 24-1073",
|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "GHISLAINE MAXWELL, Petitioner, v. UNITED STATES, Respondent.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "STATE OF NEW YORK ) COUNTY OF NEW YORK )",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "I, Rina Danielson, being duly sworn according to law and being over the age of 18, upon my oath depose and say that: I am retained by Counsel of Record for Amicus Curiae.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "That on the 9th day of May, 2025, I served the within Brief of Amicus Curiae National Association of Criminal Defense Lawyers in Support of Petitioner in the above-captioned matter upon:",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "David Oscar Markus Markus/Moss Attorneys for Petitioner 40 N.W. Third Street Penthouse One Miami, FL 33128 (305) 379-6667 dmarkus@markuslaw.com",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "D. John Sauer Solicitor General United States Department of Justice Attorneys for Respondent 950 Pennsylvania Avenue, N.W. Washington, DC 20530-0001 (202) 514-2217 SupremeCtBriefs@usdoj.gov",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "by sending three copies of same, addressed to each individual respectively, and enclosed in a properly addressed wrapper, through the United States Postal",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000215",
|
||||
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|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Ghislain Maxwell",
|
||||
"Rina Danielson",
|
||||
"David Oscar Markus",
|
||||
"D. John Sauer"
|
||||
],
|
||||
"organizations": [
|
||||
"National Association of Criminal Defense Lawyers",
|
||||
"United States Department of Justice",
|
||||
"Markus/Moss"
|
||||
],
|
||||
"locations": [
|
||||
"New York",
|
||||
"Miami, FL",
|
||||
"Washington, DC"
|
||||
],
|
||||
"dates": [
|
||||
"May 9, 2025"
|
||||
],
|
||||
"reference_numbers": [
|
||||
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|
||||
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|
||||
]
|
||||
},
|
||||
"additional_notes": "The document is a formal affidavit with printed text only. It appears to be a legal document related to a Supreme Court case."
|
||||
}
|
||||
97
results/IMAGES001/DOJ-OGR-00000216.json
Normal file
97
results/IMAGES001/DOJ-OGR-00000216.json
Normal file
@ -0,0 +1,97 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": null,
|
||||
"document_number": null,
|
||||
"date": "May 9, 2025",
|
||||
"document_type": "Notarized Affidavit",
|
||||
"has_handwriting": true,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Service, by Priority Mail, postage prepaid. An electronic version was also served by email to each individual.\n\nThat on the same date as above, I sent to this Court forty copies and 1 unbound copy of the within Amicus Curiae National Association of Criminal Defense Lawyers in Support of Petitioner through the Overnight Next Day Federal Express, postage prepaid. In addition, the brief has been submitted through the Court's electronic filing system.\n\nAll parties required to be served have been served.\n\nI declare under penalty of perjury that the foregoing is true and correct.\n\nExecuted on this 9th day of May, 2025.\n\nRina Danielson\n\nSworn to and subscribed before me this 9th day of May, 2025.\n\nMariana Braylovskiy\nNotary Public State of New York\nNo. 01BR6004935\nQualified in Richmond County\nCommission Expires March 30, 2026\n#120443",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Service, by Priority Mail, postage prepaid. An electronic version was also served by email to each individual.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "That on the same date as above, I sent to this Court forty copies and 1 unbound copy of the within Amicus Curiae National Association of Criminal Defense Lawyers in Support of Petitioner through the Overnight Next Day Federal Express, postage prepaid. In addition, the brief has been submitted through the Court's electronic filing system.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "All parties required to be served have been served.",
|
||||
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|
||||
},
|
||||
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|
||||
"type": "printed",
|
||||
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|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Executed on this 9th day of May, 2025.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "signature",
|
||||
"content": "Rina Danielson",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Rina Danielson",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Sworn to and subscribed before me this 9th day of May, 2025.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "signature",
|
||||
"content": "Mariana Braylovskiy",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "MARIANA BRAYLOVSKIY\nNotary Public State of New York\nNo. 01BR6004935\nQualified in Richmond County\nCommission Expires March 30, 2026\n#120443",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "COUNSEL PRESS\n(800) 274-3321 • (800) 359-6859\nwww.counselpress.com",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
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|
||||
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|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
"locations": [
|
||||
"New York",
|
||||
"Richmond County"
|
||||
],
|
||||
"dates": [
|
||||
"May 9, 2025",
|
||||
"March 30, 2026"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"01BR6004935",
|
||||
"#120443",
|
||||
"DOJ-OGR-00000216"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document is a notarized affidavit with a clear signature from Rina Danielson and notarization by Mariana Braylovskiy. The document appears to be well-formatted and legible."
|
||||
}
|
||||
70
results/IMAGES001/DOJ-OGR-00000241.json
Normal file
70
results/IMAGES001/DOJ-OGR-00000241.json
Normal file
@ -0,0 +1,70 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": null,
|
||||
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|
||||
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|
||||
"document_type": null,
|
||||
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|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "24-1073\nMAXWELL, GHISLAINE\nUSA\n\nSARA KROPF\nKROPF MOSELEY SCHMITT PLLC\n1100 H STREET, NW\nSUITE 1220\nWASHINGTON, DC 20005\n202-627-6900\nSARA@KMLAWFIRM.COM\n\nDAVID OSCAR MARKUS\nMARKUS/MOSS PLLC\n40 N.W. 3RD STREET\nPENTHOUSE ONE\nMIAMI, FL 33128\n305-379-6667\nDMARKUS@MARKUSLAW.COM\n\nVIA EMAIL\n\nDOJ-OGR-00000241",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
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|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "SARA KROPF\nKROPF MOSELEY SCHMITT PLLC\n1100 H STREET, NW\nSUITE 1220\nWASHINGTON, DC 20005\n202-627-6900",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "SARA@KMLAWFIRM.COM",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DAVID OSCAR MARKUS\nMARKUS/MOSS PLLC\n40 N.W. 3RD STREET\nPENTHOUSE ONE\nMIAMI, FL 33128\n305-379-6667",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "DMARKUS@MARKUSLAW.COM",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "VIA EMAIL",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
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|
||||
"position": "bottom"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
"organizations": [
|
||||
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|
||||
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|
||||
],
|
||||
"locations": [
|
||||
"WASHINGTON, DC",
|
||||
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|
||||
"USA"
|
||||
],
|
||||
"dates": [],
|
||||
"reference_numbers": [
|
||||
"24-1073",
|
||||
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|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a formal letter or correspondence, likely related to a legal matter given the presence of law firm names and addresses. The text is mostly printed, with a few email addresses highlighted or typed in a different format."
|
||||
}
|
||||
82
results/IMAGES001/DOJ-OGR-00000259.json
Normal file
82
results/IMAGES001/DOJ-OGR-00000259.json
Normal file
@ -0,0 +1,82 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 2 of 14\nthis way, EPSTEIN created a vast network of underage victims for him to sexually exploit in locations including New York and Palm Beach.\n3. The victims described herein were as young as 14 years old at the time they were abused by JEFFREY EPSTEIN, the defendant, and were, for various reasons, often particularly vulnerable to exploitation. EPSTEIN intentionally sought out minors and knew that many of his victims were in fact under the age of 18, including because, in some instances, minor victims expressly told him their age.\n4. In creating and maintaining this network of minor victims in multiple states to sexually abuse and exploit, JEFFREY EPSTEIN, the defendant, worked and conspired with others, including employees and associates who facilitated his conduct by, among other things, contacting victims and scheduling their sexual encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence.\nFACTUAL BACKGROUND\n5. During all time periods charged in this Indictment, JEFFREY EPSTEIN, the defendant, was a financier with multiple residences in the continental United States, including the New York Residence and the Palm Beach Residence.\n6. Beginning in at least 2002, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and 2\nDOJ-OGR-00000259",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
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|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "this way, EPSTEIN created a vast network of underage victims for him to sexually exploit in locations including New York and Palm Beach.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "3. The victims described herein were as young as 14 years old at the time they were abused by JEFFREY EPSTEIN, the defendant, and were, for various reasons, often particularly vulnerable to exploitation. EPSTEIN intentionally sought out minors and knew that many of his victims were in fact under the age of 18, including because, in some instances, minor victims expressly told him their age.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "4. In creating and maintaining this network of minor victims in multiple states to sexually abuse and exploit, JEFFREY EPSTEIN, the defendant, worked and conspired with others, including employees and associates who facilitated his conduct by, among other things, contacting victims and scheduling their sexual encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence.",
|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
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|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "5. During all time periods charged in this Indictment, JEFFREY EPSTEIN, the defendant, was a financier with multiple residences in the continental United States, including the New York Residence and the Palm Beach Residence.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "6. Beginning in at least 2002, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "2",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000259",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"JEFFREY EPSTEIN",
|
||||
"EPSTEIN"
|
||||
],
|
||||
"organizations": [],
|
||||
"locations": [
|
||||
"New York",
|
||||
"Palm Beach",
|
||||
"New York Residence",
|
||||
"Palm Beach Residence",
|
||||
"United States"
|
||||
],
|
||||
"dates": [
|
||||
"07/02/19",
|
||||
"2002"
|
||||
],
|
||||
"reference_numbers": [
|
||||
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|
||||
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|
||||
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|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case against Jeffrey Epstein. The text is typed, and there are no visible redactions or damage."
|
||||
}
|
||||
75
results/IMAGES001/DOJ-OGR-00000260.json
Normal file
75
results/IMAGES001/DOJ-OGR-00000260.json
Normal file
@ -0,0 +1,75 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "3",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 3 of 14\n\nrecruited, dozens of minor girls to engage in sex acts with him, after which EPSTEIN paid the victims hundreds of dollars in cash, at the New York Residence and the Palm Beach Residence.\n\n7. In both New York and Florida, JEFFREY EPSTEIN, the defendant, perpetuated this abuse in similar ways. Victims were initially recruited to provide \"massages\" to EPSTEIN, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts. EPSTEIN paid his victims hundreds of dollars in cash for each encounter. Moreover, EPSTEIN actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. EPSTEIN incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each girl that they brought to EPSTEIN. In so doing, EPSTEIN maintained a steady supply of new victims to exploit.\n\nThe New York Residence\n\n8. At all times relevant to this Indictment, JEFFREY EPSTEIN, the defendant, possessed and controlled a multi-story private residence on the Upper East Side of Manhattan, New York, i.e., the New York Residence. Between at least in or about 2002 and in or about 2005, EPSTEIN abused numerous minor victims at the New York Residence by causing these victims to be recruited to engage in paid sex acts with him.\n\n3\nDOJ-OGR-00000260",
|
||||
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||||
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||||
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||||
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||||
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|
||||
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||||
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||||
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||||
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||||
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||||
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||||
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||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
"entities": {
|
||||
"people": [
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"dates": [
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the indictment of Jeffrey Epstein. The text is typed, and there are no visible redactions or damage."
|
||||
}
|
||||
63
results/IMAGES001/DOJ-OGR-00000261.json
Normal file
63
results/IMAGES001/DOJ-OGR-00000261.json
Normal file
@ -0,0 +1,63 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "4",
|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 4 of 14\n\n9. When a victim arrived at the New York Residence, she typically would be escorted to a room with a massage table, where she would perform a massage on JEFFREY EPSTEIN, the defendant. The victims, who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress before beginning the \"massage.\" During the encounter, EPSTEIN would escalate the nature and scope of physical contact with his victim to include, among other things, sex acts such as groping and direct and indirect contact with the victim's genitals. EPSTEIN typically would also masturbate during these sexualized encounters, ask victims to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys.\n\n10. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim in cash. Victims typically were paid hundreds of dollars in cash for each encounter.\n\n11. JEFFREY EPSTEIN, the defendant, knew that many of his New York victims were underage, including because certain victims told him their age. Further, once these minor victims were recruited, many were abused by EPSTEIN on multiple subsequent occasions at the New York Residence. EPSTEIN sometimes personally contacted victims to schedule appointments at the New York Residence. In other instances, EPSTEIN directed\n\n4\nDOJ-OGR-00000261",
|
||||
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|
||||
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||||
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||||
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|
||||
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|
||||
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||||
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|
||||
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||||
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||||
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||||
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||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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||||
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||||
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||||
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|
||||
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||||
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||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case against Jeffrey Epstein. The text describes the alleged abuse of minors by Epstein at his New York Residence. The document is typed and contains no handwritten text or stamps."
|
||||
}
|
||||
63
results/IMAGES001/DOJ-OGR-00000262.json
Normal file
63
results/IMAGES001/DOJ-OGR-00000262.json
Normal file
@ -0,0 +1,63 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
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|
||||
"document_number": "2",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 5 of 14\nemployees and associates, including a New York-based employee (\"Employee-1\"), to communicate with victims via phone to arrange for these victims to return to the New York Residence for additional sexual encounters with EPSTEIN.\n12. Additionally, and to further facilitate his ability to abuse minor girls in New York, JEFFREY EPSTEIN, the defendant, asked and enticed certain of his victims to recruit additional girls to perform \"massages\" and similarly engage in sex acts with EPSTEIN. When a victim would recruit another girl for EPSTEIN, he paid both the victim-recruiter and the new victim hundreds of dollars in cash. Through these victim-recruiters, EPSTEIN gained access to and was able to abuse dozens of additional minor girls.\n13. In particular, certain recruiters brought dozens of additional minor girls to the New York Residence to give massages to and engage in sex acts with JEFFREY EPSTEIN, the defendant. EPSTEIN encouraged victims to recruit additional girls by offering to pay these victim-recruiters for every additional girl they brought to EPSTEIN. When a victim-recruiter accompanied a new minor victim to the New York Residence, both the victim-recruiter and the new minor victim were paid hundreds of dollars by EPSTEIN for each encounter. In addition, certain victim-recruiters routinely scheduled these\n5\nDOJ-OGR-00000262",
|
||||
"text_blocks": [
|
||||
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|
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|
||||
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|
||||
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|
||||
},
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
},
|
||||
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|
||||
}
|
||||
71
results/IMAGES001/DOJ-OGR-00000263.json
Normal file
71
results/IMAGES001/DOJ-OGR-00000263.json
Normal file
@ -0,0 +1,71 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 6 of 14\nencounters through Employee-1, who sometimes asked the recruiters to bring a specific minor girl for EPSTEIN.\n\nThe Palm Beach Residence\n14. In addition to recruiting and abusing minor girls in New York, JEFFREY EPSTEIN, the defendant, created a similar network of minor girls to victimize in Palm Beach, Florida, where EPSTEIN owned, possessed and controlled another large residence, i.e., the Palm Beach Residence. EPSTEIN frequently traveled from New York to Palm Beach by private jet, before which an employee or associate would ensure that minor victims were available for encounters upon his arrival in Florida.\n\n15. At the Palm Beach Residence, JEFFREY EPSTEIN, the defendant, engaged in a similar course of abusive conduct. When a victim initially arrived at the Palm Beach Residence, she would be escorted to a room, sometimes by an employee of EPSTEIN's, including, at times, two assistants (\"Employee-2\" and \"Employee-3\") who, as described herein, were also responsible for scheduling sexual encounters with minor victims. Once inside, the victim would provide a nude or semi-nude massage for EPSTEIN, who would himself typically be naked. During these encounters, EPSTEIN would escalate the nature and scope of the physical contact to include sex acts such as groping and direct and indirect contact with the victim's genitals. EPSTEIN would also typically masturbate during these encounters, ask victims\n\n- 6\nDOJ-OGR-00000263",
|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"content": "- 6",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case against Jeffrey Epstein. The text describes Epstein's alleged abuse of minor girls at his Palm Beach residence. The document is typed and contains no handwritten text or stamps."
|
||||
}
|
||||
70
results/IMAGES001/DOJ-OGR-00000264.json
Normal file
70
results/IMAGES001/DOJ-OGR-00000264.json
Normal file
@ -0,0 +1,70 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "7",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 7 of 14\nto touch him while he masturbated, and touch victims' genitals with his hands or with sex toys.\n16. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim in cash. Victims typically were paid hundreds of dollars for each encounter.\n17. JEFFREY EPSTEIN, the defendant, knew that certain of his victims were underage, including because certain victims told him their age. In addition, as with New York-based victims, many Florida victims, once recruited, were abused by JEFFREY EPSTEIN, the defendant, on multiple additional occasions.\n18. JEFFREY EPSTEIN, the defendant, who during the relevant time period was frequently in New York, would arrange for Employee-2 or other employees to contact victims by phone in advance of EPSTEIN's travel to Florida to ensure appointments were scheduled for when he arrived. In particular, in certain instances, Employee-2 placed phone calls to minor victims in Florida to schedule encounters at the Palm Beach Residence. At the time of certain of those phone calls, EPSTEIN and Employee-2 were in New York, New York. Additionally, certain of the individuals victimized at the Palm Beach Residence were contacted by phone by Employee-3 to schedule these encounters.\n7\nDOJ-OGR-00000264",
|
||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
}
|
||||
73
results/IMAGES001/DOJ-OGR-00000265.json
Normal file
73
results/IMAGES001/DOJ-OGR-00000265.json
Normal file
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|
||||
{
|
||||
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||||
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||||
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||||
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||||
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||||
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||||
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||||
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||||
"full_text": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 8 of 14\n\n19. Moreover, as in New York, to ensure a steady stream of minor victims, JEFFREY EPSTEIN, the defendant, asked and enticed certain victims in Florida to recruit other girls to engage in sex acts. EPSTEIN paid hundreds of dollars to victim-recruiters for each additional girl they brought to the Palm Beach Residence.\n\nSTATUTORY ALLEGATIONS\n\n20. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York and elsewhere, JEFFREY EPSTEIN, the defendant, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, sex trafficking of minors, in violation of Title 18, United States Code, Section 1591(a) and (b).\n\n21. It was a part and object of the conspiracy that JEFFREY EPSTEIN, the defendant, and others known and unknown, would and did, in and affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, and obtain, by any means a person, and to benefit, financially and by receiving anything of value, from participation in a venture which has engaged in any such act, knowing that the person had not attained the age of 18 years and would be caused to engage in a\n\n8\nDOJ-OGR-00000265",
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|
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|
||||
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|
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||||
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||||
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||||
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||||
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||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case against Jeffrey Epstein. The text is typed, and there are no visible stamps or handwritten notes. The document is page 8 of 14."
|
||||
}
|
||||
86
results/IMAGES001/DOJ-OGR-00000266.json
Normal file
86
results/IMAGES001/DOJ-OGR-00000266.json
Normal file
@ -0,0 +1,86 @@
|
||||
{
|
||||
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||||
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||||
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||||
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||||
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|
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"full_text": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 9 of 14\n\ncommercial sex act, in violation of Title 18, United States Code, Sections 1591(a) and (b)(2).\n\nOvert Acts\n\n22. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere:\n\na. In or about 2004, JEFFREY EPSTEIN, the defendant, enticed and recruited multiple minor victims, including minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3, to engage in sex acts with EPSTEIN at his residences in Manhattan, New York, and Palm Beach, Florida, after which he provided them with hundreds of dollars in cash for each encounter.\n\nb. In or about 2002, Minor Victim-1 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the New York Residence over a period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-1 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked Minor Victim-1 how old she was, and Minor Victim-1 answered truthfully.\n\nc. In or about 2004, Employee-1, located in the Southern District of New York, and on behalf of EPSTEIN, placed\n\n9\nDOJ-OGR-00000266",
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|
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||||
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||||
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|
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||||
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||||
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||||
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||||
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||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
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|
||||
}
|
||||
73
results/IMAGES001/DOJ-OGR-00000267.json
Normal file
73
results/IMAGES001/DOJ-OGR-00000267.json
Normal file
@ -0,0 +1,73 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
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|
||||
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|
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||||
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|
||||
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|
||||
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|
||||
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|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 10 of 14\na telephone call to Minor Victim-1 in order to schedule an appointment for Minor Victim-1 to engage in paid sex acts with EPSTEIN.\nd. In or about 2004, Minor Victim-2 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over a period of years and was paid hundreds of dollars after each encounter. EPSTEIN also encouraged and enticed Minor Victim-2 to recruit other girls to engage in paid sex acts, which she did.\ne. In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-2 in order to schedule an appointment for Minor Victim-2 to engage in paid sex acts with EPSTEIN.\nf. In or about 2005, Minor Victim-3 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over a period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-3 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked Minor Victim-3 how old she was, and Minor Victim-3 answered truthfully.\n10\nDOJ-OGR-00000267",
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to a criminal case involving Jeffrey Epstein. The text describes the alleged sexual abuse of multiple minor victims by Epstein. The document is typed and contains no handwritten text or stamps."
|
||||
}
|
||||
69
results/IMAGES001/DOJ-OGR-00000268.json
Normal file
69
results/IMAGES001/DOJ-OGR-00000268.json
Normal file
@ -0,0 +1,69 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "11",
|
||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 11 of 14\ng. In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-3 in Florida in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN.\nh. In or about 2004, Employee-3 placed a telephone call to Minor Victim-3 in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN.\n(Title 18, United States Code, Section 371.)\nCOUNT TWO\n(Sex Trafficking)\nThe Grand Jury further charges:\n23. The allegations contained in paragraphs 1 through 19 and 22 of this Indictment are repeated and realleged as if fully set forth within.\n24. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York, JEFFREY EPSTEIN, the defendant, willfully and knowingly, in and affecting interstate and foreign commerce, did recruit, entice, harbor, transport, provide, and obtain by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act, and did aid and abet the same, to wit, EPSTEIN recruited, enticed, harbored, transported, provided, and obtained numerous\n11\nDOJ-OGR-00000268",
|
||||
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|
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|
||||
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|
||||
"content": "g. In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-3 in Florida in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN.\nh. In or about 2004, Employee-3 placed a telephone call to Minor Victim-3 in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN.\n(Title 18, United States Code, Section 371.)",
|
||||
"position": "top"
|
||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
"type": "printed",
|
||||
"content": "The Grand Jury further charges:\n23. The allegations contained in paragraphs 1 through 19 and 22 of this Indictment are repeated and realleged as if fully set forth within.\n24. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York, JEFFREY EPSTEIN, the defendant, willfully and knowingly, in and affecting interstate and foreign commerce, did recruit, entice, harbor, transport, provide, and obtain by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act, and did aid and abet the same, to wit, EPSTEIN recruited, enticed, harbored, transported, provided, and obtained numerous",
|
||||
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|
||||
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|
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|
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|
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||||
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|
||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case against Jeffrey Epstein. The text is typed, and there are no visible redactions or damage."
|
||||
}
|
||||
79
results/IMAGES001/DOJ-OGR-00000269.json
Normal file
79
results/IMAGES001/DOJ-OGR-00000269.json
Normal file
@ -0,0 +1,79 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "12",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 12 of 14\n\nindividuals who were less than 18 years old, including but not limited to Minor Victim-1, as described above, and who were then caused to engage in at least one commercial sex act in Manhattan, New York.\n\n(Title 18, United States Code, Sections 1591(a), (b)(2), and 2.)\n\nFORFEITURE ALLEGATIONS\n\n25. As a result of committing the offense alleged in Count Two of this Indictment, JEFFREY EPSTEIN, the defendant, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 1594(c)(1), any property, real and personal, that was used or intended to be used to commit or to facilitate the commission of the offense alleged in Count Two, and any property, real or personal, constituting or derived from any proceeds obtained, directly or indirectly, as a result of the offense alleged in Count Two, or any property traceable to such property, and the following specific property:\n\na. The lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 9 East 71st Street, New York, New York, with block number 1386 and lot number 10, owned by Maple, Inc.\n\n12\n\nDOJ-OGR-00000269",
|
||||
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||||
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||||
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|
||||
{
|
||||
"type": "printed",
|
||||
"content": "individuals who were less than 18 years old, including but not limited to Minor Victim-1, as described above, and who were then caused to engage in at least one commercial sex act in Manhattan, New York.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "(Title 18, United States Code, Sections 1591(a), (b)(2), and 2.)",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "FORFEITURE ALLEGATIONS",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "25. As a result of committing the offense alleged in Count Two of this Indictment, JEFFREY EPSTEIN, the defendant, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 1594(c)(1), any property, real and personal, that was used or intended to be used to commit or to facilitate the commission of the offense alleged in Count Two, and any property, real or personal, constituting or derived from any proceeds obtained, directly or indirectly, as a result of the offense alleged in Count Two, or any property traceable to such property, and the following specific property:",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "a. The lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 9 East 71st Street, New York, New York, with block number 1386 and lot number 10, owned by Maple, Inc.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "12",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000269",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"JEFFREY EPSTEIN",
|
||||
"Minor Victim-1"
|
||||
],
|
||||
"organizations": [
|
||||
"Maple, Inc.",
|
||||
"United States"
|
||||
],
|
||||
"locations": [
|
||||
"Manhattan",
|
||||
"New York",
|
||||
"9 East 71st Street"
|
||||
],
|
||||
"dates": [
|
||||
"07/02/19"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"Document 2",
|
||||
"Title 18, United States Code, Sections 1591(a), (b)(2), and 2",
|
||||
"Title 18, United States Code, Section 1594(c)(1)",
|
||||
"DOJ-OGR-00000269"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case against Jeffrey Epstein. The text is typed, and there are no visible handwritten notes or stamps. The document is page 12 of 14."
|
||||
}
|
||||
80
results/IMAGES001/DOJ-OGR-00000270.json
Normal file
80
results/IMAGES001/DOJ-OGR-00000270.json
Normal file
@ -0,0 +1,80 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "13",
|
||||
"document_number": "2",
|
||||
"date": "07/02/19",
|
||||
"document_type": "Court Document",
|
||||
"has_handwriting": true,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 13 of 14\n\nSubstitute Asset Provision\n\n26. If any of the above-described forfeitable property, as a result of any act or omission of the defendant:\n\n(a) cannot be located upon the exercise of due diligence;\n(b) has been transferred or sold to, or deposited with, a third person;\n(c) has been placed beyond the jurisdiction of the Court;\n(d) has been substantially diminished in value; or\n(e) has been commingled with other property which cannot be subdivided without difficulty;\n\nit is the intent of the United States, pursuant to 21 U.S.C. § 853(p) and 28 U.S.C. § 2461(c), to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property.\n\n(Title 18, United States Code, Section 1594; Title 21, United States Code, Section 853(p); and Title 28, United States Code, Section 2461.)\n\nFOREPERSON Geoffrey S. Berman United States Attorney\n\n13\nDOJ-OGR-00000270",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 13 of 14",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Substitute Asset Provision",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "26. If any of the above-described forfeitable property, as a result of any act or omission of the defendant:\n\n(a) cannot be located upon the exercise of due diligence;\n(b) has been transferred or sold to, or deposited with, a third person;\n(c) has been placed beyond the jurisdiction of the Court;\n(d) has been substantially diminished in value; or\n(e) has been commingled with other property which cannot be subdivided without difficulty;\n\nit is the intent of the United States, pursuant to 21 U.S.C. § 853(p) and 28 U.S.C. § 2461(c), to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property.",
|
||||
"position": "main"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "(Title 18, United States Code, Section 1594; Title 21, United States Code, Section 853(p); and Title 28, United States Code, Section 2461.)",
|
||||
"position": "main"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "",
|
||||
"position": "main"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "FOREPERSON",
|
||||
"position": "signature"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "Geoffrey S. Berman",
|
||||
"position": "signature"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "United States Attorney",
|
||||
"position": "signature"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "13",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000270",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Geoffrey S. Berman"
|
||||
],
|
||||
"organizations": [
|
||||
"United States Attorney"
|
||||
],
|
||||
"locations": [],
|
||||
"dates": [
|
||||
"07/02/19"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"DOJ-OGR-00000270"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to a criminal case. It includes a provision for substitute assets and references various sections of the United States Code. The document is signed by a foreperson and Geoffrey S. Berman, the United States Attorney."
|
||||
}
|
||||
91
results/IMAGES001/DOJ-OGR-00000271.json
Normal file
91
results/IMAGES001/DOJ-OGR-00000271.json
Normal file
@ -0,0 +1,91 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "14",
|
||||
"document_number": "2",
|
||||
"date": "07/02/19",
|
||||
"document_type": "Indictment",
|
||||
"has_handwriting": true,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 14 of 14\n\nForm No. USA-33s-274 (Ed. 9-25-58)\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\nUNITED STATES OF AMERICA\n\nv.\n\nJEFFREY EPSTEIN,\nDefendant.\n\nINDICTMENT\n\n(18 U.S.C. §§ 371, 1591(a), (b)(2), and 2)\n\nGEOFFREY S. BERMAN\nUnited States Attorney\n\nSignature of Foreperson\nForeperson\n\n14\nDOJ-OGR-00000271",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 2 Filed 07/02/19 Page 14 of 14",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Form No. USA-33s-274 (Ed. 9-25-58)",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "UNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "UNITED STATES OF AMERICA\nv.\nJEFFREY EPSTEIN,\nDefendant.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "INDICTMENT",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "(18 U.S.C. §§ 371, 1591(a), (b)(2), and 2)",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "GEOFFREY S. BERMAN\nUnited States Attorney",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "Signature of Foreperson",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Foreperson",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "14",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000271",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Jeffrey Epstein",
|
||||
"Geoffrey S. Berman"
|
||||
],
|
||||
"organizations": [
|
||||
"United States District Court",
|
||||
"United States Attorney"
|
||||
],
|
||||
"locations": [
|
||||
"New York"
|
||||
],
|
||||
"dates": [
|
||||
"07/02/19",
|
||||
"9-25-58"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"Document 2",
|
||||
"DOJ-OGR-00000271"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document is an indictment against Jeffrey Epstein. It is signed by Geoffrey S. Berman, United States Attorney, and a Foreperson. The document contains a mix of printed and handwritten text."
|
||||
}
|
||||
85
results/IMAGES001/DOJ-OGR-00000272.json
Normal file
85
results/IMAGES001/DOJ-OGR-00000272.json
Normal file
@ -0,0 +1,85 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "1",
|
||||
"document_number": "3",
|
||||
"date": "07/08/19",
|
||||
"document_type": "Unsealing Order",
|
||||
"has_handwriting": true,
|
||||
"has_stamps": true
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 3 Filed 07/08/19 Page 1 of 1\nUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK\nUNITED STATES OF AMERICA - v. - JEFFREY EPSTEIN, Defendant.\nUpon the application of the United States, by the United States Attorney for the Southern District of New York, Geoffrey S. Berman, by Assistant United States Attorney Alex Rossmiller; It is found that the Indictment in the above-captioned case is currently sealed and the United States Attorney's Office has applied to have that Indictment unsealed, and it is therefore: ORDERED that the Indictment in the above-captioned action be unsealed and remain unsealed pending further order of the Court.\nDated: New York, New York July 8, 2019\nHONORABLE HENRY PITMAN UNITED STATES MAGISTRATE JUDGE SOUTHERN DISTRICT OF NEW YORK\nUSDC SDNY DOCUMENT ELECTRONICALLY FILED DOC#: FILED JUL 08 2019\nDOJ-OGR-00000272",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 3 Filed 07/08/19 Page 1 of 1",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "UNITED STATES OF AMERICA - v. - JEFFREY EPSTEIN, Defendant.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Upon the application of the United States, by the United States Attorney for the Southern District of New York, Geoffrey S. Berman, by Assistant United States Attorney Alex Rossmiller; It is found that the Indictment in the above-captioned case is currently sealed and the United States Attorney's Office has applied to have that Indictment unsealed, and it is therefore: ORDERED that the Indictment in the above-captioned action be unsealed and remain unsealed pending further order of the Court.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: New York, New York July 8, 2019",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "Henry Pitman",
|
||||
"position": "signature"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "HONORABLE HENRY PITMAN UNITED STATES MAGISTRATE JUDGE SOUTHERN DISTRICT OF NEW YORK",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "stamp",
|
||||
"content": "USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC#: FILED JUL 08 2019",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000272",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Jeffrey Epstein",
|
||||
"Geoffrey S. Berman",
|
||||
"Alex Rossmiller",
|
||||
"Henry Pitman"
|
||||
],
|
||||
"organizations": [
|
||||
"UNITED STATES DISTRICT COURT",
|
||||
"SOUTHERN DISTRICT OF NEW YORK",
|
||||
"UNITED STATES ATTORNEY'S OFFICE"
|
||||
],
|
||||
"locations": [
|
||||
"New York"
|
||||
],
|
||||
"dates": [
|
||||
"July 8, 2019",
|
||||
"07/08/19"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"Document 3",
|
||||
"19 Cr. 490",
|
||||
"DOJ-OGR-00000272"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document is a court order to unseal an indictment. It is signed by Honorable Henry Pitman, United States Magistrate Judge. The document is filed electronically and has a stamp indicating the filing date."
|
||||
}
|
||||
85
results/IMAGES001/DOJ-OGR-00000273.json
Normal file
85
results/IMAGES001/DOJ-OGR-00000273.json
Normal file
@ -0,0 +1,85 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "1",
|
||||
"document_number": "5",
|
||||
"date": "07/08/19",
|
||||
"document_type": "Court Document",
|
||||
"has_handwriting": true,
|
||||
"has_stamps": true
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 5 Filed 07/08/19 Page 1 of 1 DOCKET No. 19CR490 DEFENDANT Jeffrey Epstein AUSA Alex Rossmiller DEF.'S COUNSEL Martin Weinberg RETAINED FEDERAL DEFENDERS CJA PRESENTMENT ONLY INTERPRETER NEEDED DEFENDANT WAIVES PRETRIAL REPORT Rule 5 Rule 9 Rule 5(c)(3) Detention Hrg. DATE OF ARREST 7-6-18 TIME OF ARREST 5:70pm TIME OF PRESENTMENT 7-6-18 VOL. SURR. ON WRIT BAIL DISPOSITION DETENTION ON CONSENT W/O PREJUDICE DETENTION HEARING SCHEDULED FOR: 7-11-19 2:00 AGREED CONDITIONS OF RELEASE DEF. RELEASED ON OWN RECOGNIZANCE $ PRB $ FRP SECURED BY $ CASH/PROPERTY: TRAVEL RESTRICTED TO SDNY/EDNY/ SURRENDER TRAVEL DOCUMENTS (& NO NEW APPLICATIONS) PRETRIAL SUPERVISION: REGULAR STRICT AS DIRECTED BY PRETRIAL SERVICES DRUG TESTING/TREATMT AS DIRECTED BY PTS MENTAL HEALTH EVAL/TREATMT AS DIRECTED BY PTS DEF. TO SUBMIT TO URINALYSIS; IF POSITIVE, ADD CONDITION OF DRUG TESTING/TREATMENT HOME INCARCERATION HOME DETENTION ELECTRONIC MONITORING GPS DEF. TO PAY ALL OF PART OF COST OF LOCATION MONITORING, AS DETERMINED BY PRETRIAL SERVICES DEF. TO CONTINUE OR SEEK EMPLOYMENT [OR] DEF. TO CONTINUE OR START EDUCATION PROGRAM DEF. NOT TO POSSESS FIREARM/DESTRUCTIVE DEVICE/OTHER WEAPON DEF. TO BE DETAINED UNTIL ALL CONDITIONS ARE MET DEF. TO BE RELEASED ON OWN SIGNATURE, PLUS THE FOLLOWING CONDITIONS: ; REMAINING CONDITIONS TO BE MET BY: ADDITIONAL CONDITIONS/ADDITIONAL PROCEEDINGS/COMMENTS: - DEF'T DETAINED UNTIL CONTINUATION OF DET'N HEARING. 18 USC 3142(f) DEF. ARRAIGNED; PLEADS NOT GUILTY CONFERENCE BEFORE D.J. ON 7-8-19 DEF. WAIVES INDICTMENT SPEEDY TRIAL TIME EXCLUDED UNDER 18 U.S.C. § 3161(h)(7) UNTIL For Rule 5(c)(3) Cases: IDENTITY HEARING WAIVED DEFENDANT TO BE REMOVED PRELIMINARY HEARING IN SDNY WAIVED CONTROL DATE FOR REMOVAL: PRELIMINARY HEARING DATE: ON DEFENDANT'S CONSENT DATE: 7 8 19 UNITED STATES MAGISTRATE JUDGE, S.D.N.Y. WHITE (original) - COURT FILE PINK - U.S. ATTORNEY'S OFFICE YELLOW - U.S. MARSHAL GREEN - PRETRIAL SERVICES AGENCY Rev'd 2016 1H - 2 DOJ-OGR-00000273",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 5 Filed 07/08/19 Page 1 of 1",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOCKET No. 19CR490 DEFENDANT Jeffrey Epstein AUSA Alex Rossmiller DEF.'S COUNSEL Martin Weinberg",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "Jeffrey Epstein Martin Weinberg Alex Rossmiller",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "BAIL DISPOSITION",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "7-6-18 5:70pm 7-6-18 7-11-19 2:00",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "ADDITIONAL CONDITIONS/ADDITIONAL PROCEEDINGS/COMMENTS:",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "- DEF'T DETAINED UNTIL CONTINUATION OF DET'N HEARING. 18 USC 3142(f)",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "UNITED STATES MAGISTRATE JUDGE, S.D.N.Y.",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "stamp",
|
||||
"content": "JUL 08 2019 SDNY DOCU MENT ELECTRONICALLY FILED DATE FILED: JUL 08 2019",
|
||||
"position": "margin"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Jeffrey Epstein",
|
||||
"Alex Rossmiller",
|
||||
"Martin Weinberg"
|
||||
],
|
||||
"organizations": [
|
||||
"U.S. Attorney's Office",
|
||||
"Pretrial Services Agency"
|
||||
],
|
||||
"locations": [
|
||||
"SDNY",
|
||||
"EDNY"
|
||||
],
|
||||
"dates": [
|
||||
"07/08/19",
|
||||
"7-6-18",
|
||||
"7-11-19",
|
||||
"7-8-19"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"19CR490",
|
||||
"DOJ-OGR-00000273"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court document related to the case of Jeffrey Epstein. It contains various sections including bail disposition, additional conditions, and proceedings. The document has both printed and handwritten text, and includes a stamp indicating the date it was filed electronically."
|
||||
}
|
||||
93
results/IMAGES001/DOJ-OGR-00000274.json
Normal file
93
results/IMAGES001/DOJ-OGR-00000274.json
Normal file
@ -0,0 +1,93 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "1 of 16",
|
||||
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|
||||
"date": "07/11/19",
|
||||
"document_type": "Letter",
|
||||
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|
||||
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|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 1 of 16\n\nReid Weingarten\n1114 Avenue of the Americas\nNew York, NY 10036\n212 506 3900 main\n212 506 3955 direct\nwww.steptoe.com\nrweingarten@steptoe.com\n\nJuly 11, 2019\n\nVIA ECF\nThe Honorable Richard M. Berman\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n(212) 805-6715\n500 Pearl Street\nNew York, NY 10007\n\nRE: United States v. Jeffrey Epstein, Criminal No. 19-490\n\nDear Judge Berman:\n\nWe write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of conditions that will effectively guarantee his appearance and abate any conceivable danger he's claimed to present.\n\nIn essence, the government seeks to remand a self-made New York native and lifelong American resident based on dated allegations for which he was already convicted and punished - conduct the relitigation of which is barred by a prior federal nonprosecution agreement (the \"NPA\"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States - despite a Florida federal judge's stated belief that he could void the NPA in appropriate circumstances, possibly threatening new charges there, and notwithstanding legally erroneous government assertions in ancillary litigation that Mr. Epstein was subject to potential prosecution in other federal judicial districts, including this one specifically. Indeed, Mr. Epstein feared the toxic political climate might tempt the government to try and end-run the NPA - yet continually returned home from travel abroad, fully prepared to vindicate his rights under the agreement and otherwise mount a full-throated defense. Finally, the government takes its extreme position in the teeth of Mr. Epstein's perfect compliance with onerous sex offender registration requirements - pinpointing his exact nightly whereabouts - across multiple jurisdictions over a 10-year period.\n\n1\n\nDOJ-OGR-00000274",
|
||||
"text_blocks": [
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"content": "Reid Weingarten\n1114 Avenue of the Americas\nNew York, NY 10036\n212 506 3900 main\n212 506 3955 direct\nwww.steptoe.com\nrweingarten@steptoe.com",
|
||||
"position": "header"
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"content": "VIA ECF\nThe Honorable Richard M. Berman\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n(212) 805-6715\n500 Pearl Street\nNew York, NY 10007",
|
||||
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|
||||
},
|
||||
{
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
{
|
||||
"type": "printed",
|
||||
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|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of conditions that will effectively guarantee his appearance and abate any conceivable danger he's claimed to present.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "In essence, the government seeks to remand a self-made New York native and lifelong American resident based on dated allegations for which he was already convicted and punished - conduct the relitigation of which is barred by a prior federal nonprosecution agreement (the \"NPA\"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States - despite a Florida federal judge's stated belief that he could void the NPA in appropriate circumstances, possibly threatening new charges there, and notwithstanding legally erroneous government assertions in ancillary litigation that Mr. Epstein was subject to potential prosecution in other federal judicial districts, including this one specifically. Indeed, Mr. Epstein feared the toxic political climate might tempt the government to try and end-run the NPA - yet continually returned home from travel abroad, fully prepared to vindicate his rights under the agreement and otherwise mount a full-throated defense. Finally, the government takes its extreme position in the teeth of Mr. Epstein's perfect compliance with onerous sex offender registration requirements - pinpointing his exact nightly whereabouts - across multiple jurisdictions over a 10-year period.",
|
||||
"position": "middle"
|
||||
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|
||||
{
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
{
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"entities": {
|
||||
"people": [
|
||||
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|
||||
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|
||||
"Jeffrey Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"Steptoe & Johnson LLP",
|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
"locations": [
|
||||
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|
||||
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|
||||
"Florida",
|
||||
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|
||||
],
|
||||
"dates": [
|
||||
"July 11, 2019",
|
||||
"10-year period"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"Document 6",
|
||||
"Criminal No. 19-490",
|
||||
"DOJ-OGR-00000274"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a formal letter from Reid Weingarten to Judge Richard M. Berman regarding the case of United States v. Jeffrey Epstein. The letter is typed on Steptoe & Johnson LLP letterhead and includes a date and reference number. The content is a legal argument regarding pretrial release conditions for Jeffrey Epstein."
|
||||
}
|
||||
84
results/IMAGES001/DOJ-OGR-00000275.json
Normal file
84
results/IMAGES001/DOJ-OGR-00000275.json
Normal file
@ -0,0 +1,84 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "2",
|
||||
"document_number": "6",
|
||||
"date": "07/11/19",
|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 2 of 16\n\nNonetheless, it is fundamental that pretrial detention is reserved for \"a small but identifiable group of particularly dangerous defendants as to whom neither the imposition of stri[ct] release conditions nor the prospect of revocation of release can reasonably assure the safety of the community or other persons.\" S. Rep. No. 98-225, at 6-7 (1984), reprinted in 1984 U.S.C.C.A.N. 3182, 3189. And that's true no matter how much rhetoric and hyperbole the government and media pile on a presumptively innocent citizen. Popular condemnation aside, compelling legal issues stand between Mr. Epstein and any possible conviction on the allegations of conduct from 14 to 17 years ago pressed in the indictment. Importantly, the Bail Reform Act, 18 U.S.C. § 3141 et seq., authorizes release for even wealthy defendants facing serious charges who travel and own property abroad.\n\nThe government's indictment labels this a \"Sex Trafficking\" case. Yes, the government may have witnesses who will testify to participating in sexual massages - most over 18; some under; some who told the police they lied about their age to gain admission to Mr. Epstein's residence; some who will testify that Mr. Epstein knew they were not yet 18.1 But their anticipated testimony only punctuates the alleged offenses' purely local nature. (All occurred within a single New York residence or, if the Florida conduct is ultimately ruled admissible despite the NPA, then within two residences.) There are no allegations in the indictment that Mr. Epstein trafficked anybody for commercial profit; that he forced, coerced, defrauded, or enslaved anybody; or that he engaged in any of the other paradigmatic sex trafficking activity that 18 U.S.C. § 1591 aims to eradicate. No one seeks to minimize the gravity of the alleged conduct, but it is clear that the conduct falls within the heartland of classic state or local sex offenses - and at or outside the margins of federal criminal law.\n\nMr. Epstein, 66, is a U.S. citizen who's lived his entire life in this country. Born and bred in Coney Island, he worked his way up from humble origins - his father was a New York City municipal employee in the Parks Department - and earned every penny he's made with nothing more than a high school diploma. He speaks only English and knows no other languages. He owns no foreign businesses and holds no foreign bank accounts. Five of the six residences he maintains are located here in America. His brother, niece, and nephew all live here too.\n\nUntil his arrest in this case, Mr. Epstein's only notable brush with the law resulted in the 2007 NPA (Exhibit 1) and a 2008 state-court guilty plea required by the NPA for conduct substantially overlapping the conduct charged in the pending indictment. As a result of the state guilty plea, Mr. Epstein received a 30-month sentence, 18 months of incarceration, and 12 months' probation under conditions including home confinement. Mr. Epstein served 13 months in custody, 12 months on probation and, as a condition of the NPA and his state sentence, was required to register as a sex offender in the locations of his residences. He is currently registered\n\n1 New York's age of consent was 17 at the time of the alleged conduct and remains so today. See N.Y. Penal Law § 130.05.\n\n2\n\nDOJ-OGR-00000275",
|
||||
"text_blocks": [
|
||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"content": "Nonetheless, it is fundamental that pretrial detention is reserved for \"a small but identifiable group of particularly dangerous defendants as to whom neither the imposition of stri[ct] release conditions nor the prospect of revocation of release can reasonably assure the safety of the community or other persons.\" S. Rep. No. 98-225, at 6-7 (1984), reprinted in 1984 U.S.C.C.A.N. 3182, 3189. And that's true no matter how much rhetoric and hyperbole the government and media pile on a presumptively innocent citizen. Popular condemnation aside, compelling legal issues stand between Mr. Epstein and any possible conviction on the allegations of conduct from 14 to 17 years ago pressed in the indictment. Importantly, the Bail Reform Act, 18 U.S.C. § 3141 et seq., authorizes release for even wealthy defendants facing serious charges who travel and own property abroad.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "The government's indictment labels this a \"Sex Trafficking\" case. Yes, the government may have witnesses who will testify to participating in sexual massages - most over 18; some under; some who told the police they lied about their age to gain admission to Mr. Epstein's residence; some who will testify that Mr. Epstein knew they were not yet 18.1 But their anticipated testimony only punctuates the alleged offenses' purely local nature. (All occurred within a single New York residence or, if the Florida conduct is ultimately ruled admissible despite the NPA, then within two residences.) There are no allegations in the indictment that Mr. Epstein trafficked anybody for commercial profit; that he forced, coerced, defrauded, or enslaved anybody; or that he engaged in any of the other paradigmatic sex trafficking activity that 18 U.S.C. § 1591 aims to eradicate. No one seeks to minimize the gravity of the alleged conduct, but it is clear that the conduct falls within the heartland of classic state or local sex offenses - and at or outside the margins of federal criminal law.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Mr. Epstein, 66, is a U.S. citizen who's lived his entire life in this country. Born and bred in Coney Island, he worked his way up from humble origins - his father was a New York City municipal employee in the Parks Department - and earned every penny he's made with nothing more than a high school diploma. He speaks only English and knows no other languages. He owns no foreign businesses and holds no foreign bank accounts. Five of the six residences he maintains are located here in America. His brother, niece, and nephew all live here too.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Until his arrest in this case, Mr. Epstein's only notable brush with the law resulted in the 2007 NPA (Exhibit 1) and a 2008 state-court guilty plea required by the NPA for conduct substantially overlapping the conduct charged in the pending indictment. As a result of the state guilty plea, Mr. Epstein received a 30-month sentence, 18 months of incarceration, and 12 months' probation under conditions including home confinement. Mr. Epstein served 13 months in custody, 12 months on probation and, as a condition of the NPA and his state sentence, was required to register as a sex offender in the locations of his residences. He is currently registered",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "1 New York's age of consent was 17 at the time of the alleged conduct and remains so today. See N.Y. Penal Law § 130.05.",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "2",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000275",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Mr. Epstein",
|
||||
"Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"Parks Department"
|
||||
],
|
||||
"locations": [
|
||||
"New York",
|
||||
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|
||||
"Florida",
|
||||
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|
||||
],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"14 to 17 years ago",
|
||||
"2007",
|
||||
"2008"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"Document 6",
|
||||
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|
||||
"18 U.S.C. § 3141",
|
||||
"18 U.S.C. § 1591",
|
||||
"N.Y. Penal Law § 130.05",
|
||||
"DOJ-OGR-00000275"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein, with a focus on his background and the nature of the charges against him. The text is printed and there are no visible stamps or handwritten notes. The document is page 2 of 16."
|
||||
}
|
||||
83
results/IMAGES001/DOJ-OGR-00000276.json
Normal file
83
results/IMAGES001/DOJ-OGR-00000276.json
Normal file
@ -0,0 +1,83 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "3",
|
||||
"document_number": "6",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 3 of 16\n\nin the U.S. Virgin Islands, his principal residence, Florida, and New York. Mr. Epstein has scrupulously fulfilled his obligations in every jurisdiction in which he was required to register throughout the 10-year hiatus between his release and present arrest. All of his travel has been meticulously reported to the registration authorities so that they have been aware of his precise location every single day for the past 10 years. Better still, the pending charges date back 14-17 years, from 2002 to 2005. Yet, tellingly, they allege no recurrence of the conduct underlying the NPA and Florida state conviction at any time in the ensuing decade and a half (2005-2019). Together, these unique factors are powerful indicia that Mr. Epstein is no longer a danger to anyone and will faithfully obey all conditions of release if ordered.\n\nIn sum, Mr. Epstein has substantial grounds to challenge the allegations charged by the government in its indictment, and he has every intention of doing so in a lawful, professional, and principled manner. He intends to fight the current charges on their merits and, more, to contest their legality given the inextricable intertwining of the current investigation and his NPA which promised him immunity and a global settlement for offenses including those brought under 18 U.S.C. § 1591. Any perception that Mr. Epstein poses any conceivable danger or flight risk may be readily dispelled by a slate of highly restrictive conditions, which amply suffice to secure his release:\n\n1. Home detention in Mr. Epstein's Manhattan residence, with permission to leave only for medical appointments as approved by Pretrial Services, including (at the Court's discretion) the installation of surveillance cameras at the front and rear entrances to ensure compliance.\n2. Electronic monitoring with a Global Positioning System.²\n3. An agreement not to seek or obtain any new passport during the pendency of this matter.³\n\n² \"A radio frequency ('RF') bracelet is the more conventional 'ankle bracelet' that has been used over time. GPS monitoring is a more recent phenomenon that is distinct from RF monitoring. While both units are placed on the ankle, the former tracks an offender's movements in real time, while the latter is contingent upon proximity to a base unit connected to a landline at an offender's home. Statistically, GPS monitoring is more effective than RF monitoring at preventing recidivism.\" United States v. Paulino, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018) (citations omitted).\n\n³ Mr. Epstein has only one active passport permitting current travel – not three, as the government fancies. That one active U.S. passport has now been surrendered. Mr. Epstein has no foreign passports.\n\n3\nDOJ-OGR-00000276",
|
||||
"text_blocks": [
|
||||
{
|
||||
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|
||||
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|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "in the U.S. Virgin Islands, his principal residence, Florida, and New York. Mr. Epstein has scrupulously fulfilled his obligations in every jurisdiction in which he was required to register throughout the 10-year hiatus between his release and present arrest. All of his travel has been meticulously reported to the registration authorities so that they have been aware of his precise location every single day for the past 10 years. Better still, the pending charges date back 14-17 years, from 2002 to 2005. Yet, tellingly, they allege no recurrence of the conduct underlying the NPA and Florida state conviction at any time in the ensuing decade and a half (2005-2019). Together, these unique factors are powerful indicia that Mr. Epstein is no longer a danger to anyone and will faithfully obey all conditions of release if ordered.",
|
||||
"position": "main"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "In sum, Mr. Epstein has substantial grounds to challenge the allegations charged by the government in its indictment, and he has every intention of doing so in a lawful, professional, and principled manner. He intends to fight the current charges on their merits and, more, to contest their legality given the inextricable intertwining of the current investigation and his NPA which promised him immunity and a global settlement for offenses including those brought under 18 U.S.C. § 1591. Any perception that Mr. Epstein poses any conceivable danger or flight risk may be readily dispelled by a slate of highly restrictive conditions, which amply suffice to secure his release:",
|
||||
"position": "main"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "1. Home detention in Mr. Epstein's Manhattan residence, with permission to leave only for medical appointments as approved by Pretrial Services, including (at the Court's discretion) the installation of surveillance cameras at the front and rear entrances to ensure compliance.\n2. Electronic monitoring with a Global Positioning System.²\n3. An agreement not to seek or obtain any new passport during the pendency of this matter.³",
|
||||
"position": "main"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "² \"A radio frequency ('RF') bracelet is the more conventional 'ankle bracelet' that has been used over time. GPS monitoring is a more recent phenomenon that is distinct from RF monitoring. While both units are placed on the ankle, the former tracks an offender's movements in real time, while the latter is contingent upon proximity to a base unit connected to a landline at an offender's home. Statistically, GPS monitoring is more effective than RF monitoring at preventing recidivism.\" United States v. Paulino, 335 F. Supp. 3d 600, 617 n.5 (S.D.N.Y. 2018) (citations omitted).",
|
||||
"position": "footnote"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "³ Mr. Epstein has only one active passport permitting current travel – not three, as the government fancies. That one active U.S. passport has now been surrendered. Mr. Epstein has no foreign passports.",
|
||||
"position": "footnote"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "3",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000276",
|
||||
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|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Mr. Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"Pretrial Services",
|
||||
"Court"
|
||||
],
|
||||
"locations": [
|
||||
"U.S. Virgin Islands",
|
||||
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|
||||
"New York",
|
||||
"Manhattan"
|
||||
],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"2002",
|
||||
"2005",
|
||||
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|
||||
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|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"Document 6",
|
||||
"18 U.S.C. § 1591",
|
||||
"335 F. Supp. 3d 600",
|
||||
"DOJ-OGR-00000276"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein, discussing his compliance with registration requirements and proposing conditions for his release."
|
||||
}
|
||||
69
results/IMAGES001/DOJ-OGR-00000277.json
Normal file
69
results/IMAGES001/DOJ-OGR-00000277.json
Normal file
@ -0,0 +1,69 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "4",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 4 of 16\n4. Consent to U.S. extradition from any country and waiver of all rights against such extradition.4\n5. A substantial personal recognizance bond in an amount set by the Court after reviewing additional information regarding Mr. Epstein's finances, which Mr. Epstein will seek the Court's permission to provide via sealed supplemental disclosure.\n6. The bond shall be secured by a mortgage on the Manhattan residence, valued at roughly $77 million. Mr. Epstein's private jet can be pledged as further collateral.\n7. Mr. Epstein's brother Mark will serve as a co-surety of the bond, which shall be further secured by a mortgage on Mark's home in West Palm Beach, Florida. Mr. Epstein's friend David Mitchell will also serve as a co-surety and pledge his investment interests in two properties to secure the bond.\n8. Mr. Epstein shall deregister or otherwise ground his private jet.5\n9. He shall demobilize, ground, and/or deregister all vehicles or any other means of transportation in the New York area, providing particularized information as to each vehicle's location.\n10. Mr. Epstein will provide Pretrial Services and/or the government random access to his residence.\n11. No person shall enter the residence, other than Mr. Epstein and his attorneys, without prior approval from Pretrial Services and/or the Court.\n12. Mr. Epstein will report daily by telephone to Pretrial Services (or on any other schedule the Court deems appropriate).\n13. A Trustee or Trustees will be appointed to live in Mr. Epstein's residence and report any violation to Pretrial Services and/or the Court.\n14. Any other condition the Court deems necessary to reasonably assure Mr. Epstein's appearance.\nI. Applicable law\nEchoing and reinforcing the presumption of innocence, our justice system's bedrock, there is a \"strong presumption against [pretrial] detention.\" United States v. Hanson, 613 F. Supp. 2d 85, 87 (D.D.C. 2009). A person facing trial generally must be released so long as some \"condition, or combination of conditions . . . [can] reasonably assure the appearance of the person as required and the safety of any other person and the community.\" 18 U.S.C. § 3142(c). \"Only in rare circumstances should release be denied.\" United States v. Motamedi, 767 F.2d 1403, 1405 (9th Cir. 1985). Any doubts as to the propriety of release are resolved in the defendant's favor. See United States v. Chen, 820 F. Supp. 1205, 1207 (N.D. Cal. 1992).\n4 Mr. Epstein's lone foreign residence is in Paris; France has an extradition treaty with the United States.\n5 Mr. Epstein owns one private jet. He sold the other jet in June 2019.\nDOJ-OGR-00000277",
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||||
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||||
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||||
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|
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|
||||
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||||
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|
||||
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||||
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||||
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|
||||
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|
||||
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|
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
59
results/IMAGES001/DOJ-OGR-00000278.json
Normal file
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||||
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||||
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"page_number": "5",
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"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 5 of 16\n\nThough the Bail Reform Act contains a rebuttable presumption in favor of detention based on the crimes charged, the presumption shifts only the burden of production, not persuasion. See United States v. Martir, 782 F.2d 1141, 1144 (2d Cir. 1986). Accordingly, the statutory demand on defendants \"is fairly easily met.\" United States v. Conway, No. 4-11-70756, 2011 WL 3421321, at *2 (N.D. Cal. Aug. 3, 2011). To rebut the presumption, a defendant need only \"show that the specific nature of the crimes charged, or that something about their individual circumstances, suggests that 'what is true in general is not true in the particular case . . .'\" United States v. Dominguez, 783 F.2d 702, 707 (7th Cir. 1986) (quoting United States v. Jessup, 757 F.2d 378, 384 (1st Cir.1985)). \"The quantum of evidence required to rebut the presumption is not high.\" United States v. Thompson, No. 16-CR-00019, 2018 WL 447331, at *2 (M.D. Pa. Jan. 17, 2018) (citation omitted). \"Any evidence favorable to a defendant that comes within a category listed in § 3142(g) can affect the operation of [the presumption], including evidence of their marital, family and employment status, ties to and role in the community, clean criminal record and other types of evidence encompassed in § 3142(g)(3).\" Dominguez, 783 F.2d at 707 (clean record plus socioeconomic stability sufficed to rebut presumption).\n\nIn short, evidence that the defendant is unlikely to flee or commit crimes rebuts the presumption, forcing the government to persuade the court that detention is warranted. See Conway, 2011 WL 3421321, at *5 (§ 1591 defendant released pending trial). While not disappearing entirely, the presumption thus recedes to one factor among many in determining whether there are sufficient conditions to \"reasonably assure\" both presence and safety. See Martir, 782 F.2d at 1144; see also United States v. Orta, 760 F.2d 887, 891 (8th Cir. 1985) (\"[R]easonably assure\" doesn't mean \"guarantee.\") Even in a presumption case, then, \"the government retains the ultimate burden of persuasion by clear and convincing evidence that the defendant presents a danger to the community,\" and by a \"preponderance\" that he poses a flight \"risk.\" United States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (citation and internal quotation marks omitted).\n\nII. Mr. Epstein's 14-year record of law-abiding behavior rebuts any presumption in favor of pretrial detention\n\nIn this case, any danger presumption attending the § 1591 charges evaporates against Mr. Epstein's meticulous obedience, from 2005 to date, to both the law's commands and his rigorous registration and reporting obligations as a convicted sex offender. The indictment does not allege that Mr. Epstein committed any crime in the 14-year interval between the end of the alleged conduct and the initiation of this case. The dangerousness prong of the Bail Reform Act is predictive, asking whether it's likely that Mr. Epstein will reoffend if released. A spotless 14-year record of walking the straight and narrow, complemented by an exemplary 10-year history of diligent sex offender registration and reporting, is compelling proof he was able, once the prior investigation commenced, to conform his conduct to the law's dictates. The time lag between the offenses charged and today is particularly compelling in terms of a prediction of",
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"content": "Though the Bail Reform Act contains a rebuttable presumption in favor of detention based on the crimes charged, the presumption shifts only the burden of production, not persuasion. See United States v. Martir, 782 F.2d 1141, 1144 (2d Cir. 1986). Accordingly, the statutory demand on defendants \"is fairly easily met.\" United States v. Conway, No. 4-11-70756, 2011 WL 3421321, at *2 (N.D. Cal. Aug. 3, 2011). To rebut the presumption, a defendant need only \"show that the specific nature of the crimes charged, or that something about their individual circumstances, suggests that 'what is true in general is not true in the particular case . . .'\" United States v. Dominguez, 783 F.2d 702, 707 (7th Cir. 1986) (quoting United States v. Jessup, 757 F.2d 378, 384 (1st Cir.1985)). \"The quantum of evidence required to rebut the presumption is not high.\" United States v. Thompson, No. 16-CR-00019, 2018 WL 447331, at *2 (M.D. Pa. Jan. 17, 2018) (citation omitted). \"Any evidence favorable to a defendant that comes within a category listed in § 3142(g) can affect the operation of [the presumption], including evidence of their marital, family and employment status, ties to and role in the community, clean criminal record and other types of evidence encompassed in § 3142(g)(3).\" Dominguez, 783 F.2d at 707 (clean record plus socioeconomic stability sufficed to rebut presumption).\n\nIn short, evidence that the defendant is unlikely to flee or commit crimes rebuts the presumption, forcing the government to persuade the court that detention is warranted. See Conway, 2011 WL 3421321, at *5 (§ 1591 defendant released pending trial). While not disappearing entirely, the presumption thus recedes to one factor among many in determining whether there are sufficient conditions to \"reasonably assure\" both presence and safety. See Martir, 782 F.2d at 1144; see also United States v. Orta, 760 F.2d 887, 891 (8th Cir. 1985) (\"[R]easonably assure\" doesn't mean \"guarantee.\") Even in a presumption case, then, \"the government retains the ultimate burden of persuasion by clear and convincing evidence that the defendant presents a danger to the community,\" and by a \"preponderance\" that he poses a flight \"risk.\" United States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (citation and internal quotation marks omitted).\n\nII. Mr. Epstein's 14-year record of law-abiding behavior rebuts any presumption in favor of pretrial detention\n\nIn this case, any danger presumption attending the § 1591 charges evaporates against Mr. Epstein's meticulous obedience, from 2005 to date, to both the law's commands and his rigorous registration and reporting obligations as a convicted sex offender. The indictment does not allege that Mr. Epstein committed any crime in the 14-year interval between the end of the alleged conduct and the initiation of this case. The dangerousness prong of the Bail Reform Act is predictive, asking whether it's likely that Mr. Epstein will reoffend if released. A spotless 14-year record of walking the straight and narrow, complemented by an exemplary 10-year history of diligent sex offender registration and reporting, is compelling proof he was able, once the prior investigation commenced, to conform his conduct to the law's dictates. The time lag between the offenses charged and today is particularly compelling in terms of a prediction of",
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||||
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||||
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||||
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||||
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||||
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|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein, discussing the Bail Reform Act and pretrial detention. The text is printed and there are no visible stamps or handwritten notes. The document is page 5 of 16."
|
||||
}
|
||||
72
results/IMAGES001/DOJ-OGR-00000279.json
Normal file
72
results/IMAGES001/DOJ-OGR-00000279.json
Normal file
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||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 6 of 16\n\nfuture danger when viewed in the context of the unparalleled global media attention the case has garnered, including the creation of a website by the government requesting witnesses claiming abuse to come forward. Accordingly, any danger that Mr. Epstein may have once posed to the community has long since abated. At the very least, this enormous gap in time precludes a finding by clear and convincing evidence that no conditions of release can reasonably assure the community's safety.6\n\nThe rebuttable presumption of a risk of flight is negated by the evidence that the government had stated it believed it could prosecute Mr. Epstein for the very same conduct for which he was immunized, albeit in a second jurisdiction, despite the protections conferred upon him under the NPA. Mr. Epstein's continuous presence in the United States even while he had a residence out of the country reinforces the point. As detailed below, Mr. Epstein understood the NPA as a global resolution of any charges arising from the alleged conduct at issue here, including conduct in New York. Indeed, the government, in a Southern District of Florida filing\n\n6 The government vastly overreaches in painting Mr. Epstein as dangerous based on musty plea discussions. The government's argument that Mr. Epstein's release would risk obstructive behavior, at pages 8-9 of its submission, rests primarily upon statements made between Mr. Epstein's prior counsel and an Assistant U.S. Attorney while they searched for a federal offense, at the government's behest, with a one-year statutory maximum or guideline during the give-and-take of those of plea negotiations. The communication from prior counsel about a potential proffer for a federal charge was met with the response that there was no sufficient evidence to charge such an offense. These purported facts were mere allegations that did not ultimately manifest themselves in any agreement by Mr. Epstein - nor in any agreement that probable cause existed to support any obstruction or assault charge. And the documents from the Southern District of Florida litigation referenced by the government in support of its argument on this point expressly acknowledge this lack of substantiation. See Jane Doe #1 and Jane Doe #2 v. United States, 08-CV-80736 (S.D. Fla.), Dkt. 361-10 (prosecutor stating, \"[o]n the obstruction charges, many of the facts that I included in that first proffer were hypothesized based upon our discussions and the agents' observations of [redacted]. We will need to interview her to confirm the accuracy of those facts . . .\"), Dkt. 361-11 (prosecutor stating, \"I know that someone mentioned there being activity on an airplane, I just wanted to make sure that there is factual basis for the plea that the agents can confirm\"), Dkt. 361-9 (prosecutor stating, \"I don't know the factual basis for the alleged [redacted] because we have no independent evidence of that\"). In short, these were suggested hypotheses not facts, and the government itself ultimately did not believe there was factual support for the allegations. They do not provide a sufficiently reliable factual basis for any finding by clear and convincing evidence. As to the suggestion by the prosecutor that a charge could be predicated on a prior incident where it was alleged that an investigator forced a family member of a witness off the road, the defense is without knowledge as to the basis for this allegation and the conduct, if it occurred, was not attributable to or authorized by Mr. Epstein.\n\n6\nDOJ-OGR-00000279",
|
||||
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"content": "future danger when viewed in the context of the unparalleled global media attention the case has garnered, including the creation of a website by the government requesting witnesses claiming abuse to come forward. Accordingly, any danger that Mr. Epstein may have once posed to the community has long since abated. At the very least, this enormous gap in time precludes a finding by clear and convincing evidence that no conditions of release can reasonably assure the community's safety.6",
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"content": "The rebuttable presumption of a risk of flight is negated by the evidence that the government had stated it believed it could prosecute Mr. Epstein for the very same conduct for which he was immunized, albeit in a second jurisdiction, despite the protections conferred upon him under the NPA. Mr. Epstein's continuous presence in the United States even while he had a residence out of the country reinforces the point. As detailed below, Mr. Epstein understood the NPA as a global resolution of any charges arising from the alleged conduct at issue here, including conduct in New York. Indeed, the government, in a Southern District of Florida filing",
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||||
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|
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},
|
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{
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"type": "printed",
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"content": "6 The government vastly overreaches in painting Mr. Epstein as dangerous based on musty plea discussions. The government's argument that Mr. Epstein's release would risk obstructive behavior, at pages 8-9 of its submission, rests primarily upon statements made between Mr. Epstein's prior counsel and an Assistant U.S. Attorney while they searched for a federal offense, at the government's behest, with a one-year statutory maximum or guideline during the give-and-take of those of plea negotiations. The communication from prior counsel about a potential proffer for a federal charge was met with the response that there was no sufficient evidence to charge such an offense. These purported facts were mere allegations that did not ultimately manifest themselves in any agreement by Mr. Epstein - nor in any agreement that probable cause existed to support any obstruction or assault charge. And the documents from the Southern District of Florida litigation referenced by the government in support of its argument on this point expressly acknowledge this lack of substantiation. See Jane Doe #1 and Jane Doe #2 v. United States, 08-CV-80736 (S.D. Fla.), Dkt. 361-10 (prosecutor stating, \"[o]n the obstruction charges, many of the facts that I included in that first proffer were hypothesized based upon our discussions and the agents' observations of [redacted]. We will need to interview her to confirm the accuracy of those facts . . .\"), Dkt. 361-11 (prosecutor stating, \"I know that someone mentioned there being activity on an airplane, I just wanted to make sure that there is factual basis for the plea that the agents can confirm\"), Dkt. 361-9 (prosecutor stating, \"I don't know the factual basis for the alleged [redacted] because we have no independent evidence of that\"). In short, these were suggested hypotheses not facts, and the government itself ultimately did not believe there was factual support for the allegations. They do not provide a sufficiently reliable factual basis for any finding by clear and convincing evidence. As to the suggestion by the prosecutor that a charge could be predicated on a prior incident where it was alleged that an investigator forced a family member of a witness off the road, the defense is without knowledge as to the basis for this allegation and the conduct, if it occurred, was not attributable to or authorized by Mr. Epstein.",
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||||
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|
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|
||||
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|
||||
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|
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|
||||
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|
||||
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|
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|
||||
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|
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|
||||
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|
||||
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|
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein. The text is mostly printed, with some redacted sections. The document includes references to specific court documents and proceedings."
|
||||
}
|
||||
78
results/IMAGES001/DOJ-OGR-00000280.json
Normal file
78
results/IMAGES001/DOJ-OGR-00000280.json
Normal file
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||||
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||||
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|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 7 of 16\n\nthat was unsealed and became public in July 2013, specifically noted that \"a number of districts outside the Southern District of Florida (e.g., the Southern District of New York and the District of New Jersey) share jurisdiction and venue with the Southern District of Florida over potential federal criminal charges based on the alleged sexual acts committed by Epstein against the Petitioners. Epstein is thus subject to potential prosecution for such acts in those districts.\" Exhibit 2, Jane Doe #1 and Jane Doe #2 v. United States, 08-CV-80736 (S.D. Fla. July 5, 2013), Dkt. 205-2, at 9. The government went so far as to invite the alleged victims \"to contact the United States Attorney's Office in those districts and seek to confer with government attorneys in those offices about investigating and potentially prosecuting Epstein based on the alleged federal crimes committed against them.\" Id. at 10. The Florida U.S. Attorney's Office even offered to share the evidence gathered in its investigation with prosecutors and grand juries in the other relevant jurisdictions. See id. at 10 n.9.\n\nThe defense strongly disagrees with the premise that the government can offer and execute an immunity or nonprosecution agreement with a citizen in the location of one of two venues where an interstate telephone call (or flight or any form of wire or mail communication) occurs and then circumvent the consequences of that immunity grant by having the very same prosecution office promote and motivate a prosecution by another office at the second venue of prosecution what in fact was a single criminal transaction. What is significant for bail purposes is that notwithstanding this notice of the government's illegal position, and his knowledge of the substantial penalties that he would face if charged and convicted, Mr. Epstein made no attempt to flee in the approximately six years preceding his arrest. During that time, as noted by the government, he engaged in substantial international travel, always returning to his residences in the United States. Mr. Epstein never sought to obtain dual citizenship or took any other steps indicative of an intent to flee. This fact significantly undermines the government's contentions regarding risk of flight and indicates Mr. Epstein's good-faith intent to contest the charges pending against him.\n\nOn September 24, 2007, after a year-long investigation, the Department of Justice, through the United States Attorney for the Southern District of Florida (\"USAO-SDFL\"), entered into the NPA with Mr. Epstein. The NPA immunized Mr. Epstein from five distinct potential federal charges that \"may have been committed by Epstein . . . from in or around 2001 through in or around September 2007.\" Exhibit 1, NPA, at 1-2. One of the federal charges was 18 U.S.C. § 1591, the statute charged in this SDNY case. The time period covered by the NPA subsumes the entire time period charged in this SDNY case. The USAO-SDFL acknowledged in the NPA that the very premise for Mr. Epstein to enter into it was \"to resolve globally his state and federal criminal liability . . .\" Id. at 2 (emphasis added). Senior officials at the Department of Justice reviewed the NPA and either authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the \"CVRA litigation\") (illustrating the number of prosecutors involved in the decision-making over the NPA).\n\n7\nDOJ-OGR-00000280",
|
||||
"text_blocks": [
|
||||
{
|
||||
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|
||||
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|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "that was unsealed and became public in July 2013, specifically noted that \"a number of districts outside the Southern District of Florida (e.g., the Southern District of New York and the District of New Jersey) share jurisdiction and venue with the Southern District of Florida over potential federal criminal charges based on the alleged sexual acts committed by Epstein against the Petitioners. Epstein is thus subject to potential prosecution for such acts in those districts.\" Exhibit 2, Jane Doe #1 and Jane Doe #2 v. United States, 08-CV-80736 (S.D. Fla. July 5, 2013), Dkt. 205-2, at 9. The government went so far as to invite the alleged victims \"to contact the United States Attorney's Office in those districts and seek to confer with government attorneys in those offices about investigating and potentially prosecuting Epstein based on the alleged federal crimes committed against them.\" Id. at 10. The Florida U.S. Attorney's Office even offered to share the evidence gathered in its investigation with prosecutors and grand juries in the other relevant jurisdictions. See id. at 10 n.9.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "The defense strongly disagrees with the premise that the government can offer and execute an immunity or nonprosecution agreement with a citizen in the location of one of two venues where an interstate telephone call (or flight or any form of wire or mail communication) occurs and then circumvent the consequences of that immunity grant by having the very same prosecution office promote and motivate a prosecution by another office at the second venue of prosecution what in fact was a single criminal transaction. What is significant for bail purposes is that notwithstanding this notice of the government's illegal position, and his knowledge of the substantial penalties that he would face if charged and convicted, Mr. Epstein made no attempt to flee in the approximately six years preceding his arrest. During that time, as noted by the government, he engaged in substantial international travel, always returning to his residences in the United States. Mr. Epstein never sought to obtain dual citizenship or took any other steps indicative of an intent to flee. This fact significantly undermines the government's contentions regarding risk of flight and indicates Mr. Epstein's good-faith intent to contest the charges pending against him.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "On September 24, 2007, after a year-long investigation, the Department of Justice, through the United States Attorney for the Southern District of Florida (\"USAO-SDFL\"), entered into the NPA with Mr. Epstein. The NPA immunized Mr. Epstein from five distinct potential federal charges that \"may have been committed by Epstein . . . from in or around 2001 through in or around September 2007.\" Exhibit 1, NPA, at 1-2. One of the federal charges was 18 U.S.C. § 1591, the statute charged in this SDNY case. The time period covered by the NPA subsumes the entire time period charged in this SDNY case. The USAO-SDFL acknowledged in the NPA that the very premise for Mr. Epstein to enter into it was \"to resolve globally his state and federal criminal liability . . .\" Id. at 2 (emphasis added). Senior officials at the Department of Justice reviewed the NPA and either authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the \"CVRA litigation\") (illustrating the number of prosecutors involved in the decision-making over the NPA).",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "7",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000280",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Epstein",
|
||||
"Jane Doe #1",
|
||||
"Jane Doe #2",
|
||||
"Mr. Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"Department of Justice",
|
||||
"United States Attorney's Office",
|
||||
"USAO-SDFL"
|
||||
],
|
||||
"locations": [
|
||||
"Southern District of Florida",
|
||||
"Southern District of New York",
|
||||
"District of New Jersey",
|
||||
"United States"
|
||||
],
|
||||
"dates": [
|
||||
"July 2013",
|
||||
"July 5, 2013",
|
||||
"September 24, 2007",
|
||||
"2001",
|
||||
"September 2007"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"Document 6",
|
||||
"08-CV-80736",
|
||||
"Dkt. 205-2",
|
||||
"Dkt. 329-1",
|
||||
"18 U.S.C. § 1591"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case against Jeffrey Epstein. The text is printed and there are no visible stamps or handwritten notes. The document is page 7 of 16."
|
||||
}
|
||||
69
results/IMAGES001/DOJ-OGR-00000281.json
Normal file
69
results/IMAGES001/DOJ-OGR-00000281.json
Normal file
@ -0,0 +1,69 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "8",
|
||||
"document_number": "6",
|
||||
"date": "07/11/19",
|
||||
"document_type": "court document",
|
||||
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|
||||
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|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 8 of 16\n\nThe NPA required Mr. Epstein to plead guilty to a state felony charge (Fla. Stat. § 796.07), then pending in the State of Florida and to an additional state felony charge (not previously charged or required by the State) of violating Fla. Stat. § 796.03 (Case No. 2008-CF-9381AXX), a charge requiring registration as a sex offender. Mr. Epstein complied with all of his obligations under the NPA.\n\nContrary to the government's argument, the NPA was not limited to a \"list of several dozen victims identified in the prior investigation . . . .\" Gov't Bail Letter at 6-7. Indeed, the NPA contains no \"list of several dozen victims\" and regardless, the NPA immunized Mr. Epstein from prosecution \"for the offenses set out on pages 1 and 2 of this Agreement,\" allegedly committed between 2001-07, as well as \"any offenses that arose from the Federal Grand Jury investigation.\" NPA at 2 (emphasis added). Moreover, the government's interpretation that the NPA \"pertained exclusively to the SDFL investigation\" and \"did not purport to bind any other Office or District\" will be the subject of a major dispute in this case. This is especially so because Mr. Epstein's alleged conduct at his Palm Beach residence features prominently in the conspiracy count (Count 1, ¶¶ 14-19, ¶ 22.a, d, f) and is incorporated by reference in the substantive charge (Count 2, ¶ 23).\n\nBeyond that, Mr. Epstein intends to raise and litigate significant due process issues about the Department of Justice's conduct in this case. Namely, there is irrefutable evidence from the pending CVRA litigation in the Southern District of Florida that, after Mr. Epstein had fully complied with his obligations under the NPA, the USAO-SDFL affirmatively encouraged alleged victims to pursue prosecution of Mr. Epstein in other districts, in violation of the DOJ's commitment to a \"global\" resolution. See Exhibit 2, at 8-12. The United States Attorney for the Southern District of Florida, along with supervisory and line prosecutors from the USAO-SDFL, corresponded on multiple occasions with, and personally conferred with, alleged victims and their lawyers to entertain discussions about the alleged victims' desire to have Mr. Epstein prosecuted on federal charges. See id. at 9. Further, the Southern District of New York is likely relying upon physical evidence seized in connection with the prior investigation, see Gov't Bail Letter at 6 (discussing \"corroborating evidence,\" including \"contemporaneous notes, messages . . . , and call records\"). In short, there will be evidence that the current New York case is not truly independent of the prior immunized conduct. The evidence will show that Mr. Epstein's reasonable expectation that the NPA would \"resolve globally [Mr. Epstein's] state and federal criminal liability\" in exchange for Mr. Epstein's compliance with the duties and obligations in the NPA - which he fully performed - has been unconstitutionally undermined by the government's efforts to minimize the potential consequences of a CVRA conferral violation (one that neither the government nor defense believes occurred but that was found to have occurred in the CVRA litigation which is pending a decision on remedies) by returning an inextricably intertwined second federal prosecution just as the District Court in Florida is receiving submissions on remedy.\n\n8\nDOJ-OGR-00000281",
|
||||
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|
||||
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|
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|
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|
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"position": "header"
|
||||
},
|
||||
{
|
||||
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|
||||
"content": "The NPA required Mr. Epstein to plead guilty to a state felony charge (Fla. Stat. § 796.07), then pending in the State of Florida and to an additional state felony charge (not previously charged or required by the State) of violating Fla. Stat. § 796.03 (Case No. 2008-CF-9381AXX), a charge requiring registration as a sex offender. Mr. Epstein complied with all of his obligations under the NPA.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Contrary to the government's argument, the NPA was not limited to a \"list of several dozen victims identified in the prior investigation . . . .\" Gov't Bail Letter at 6-7. Indeed, the NPA contains no \"list of several dozen victims\" and regardless, the NPA immunized Mr. Epstein from prosecution \"for the offenses set out on pages 1 and 2 of this Agreement,\" allegedly committed between 2001-07, as well as \"any offenses that arose from the Federal Grand Jury investigation.\" NPA at 2 (emphasis added). Moreover, the government's interpretation that the NPA \"pertained exclusively to the SDFL investigation\" and \"did not purport to bind any other Office or District\" will be the subject of a major dispute in this case. This is especially so because Mr. Epstein's alleged conduct at his Palm Beach residence features prominently in the conspiracy count (Count 1, ¶¶ 14-19, ¶ 22.a, d, f) and is incorporated by reference in the substantive charge (Count 2, ¶ 23).",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Beyond that, Mr. Epstein intends to raise and litigate significant due process issues about the Department of Justice's conduct in this case. Namely, there is irrefutable evidence from the pending CVRA litigation in the Southern District of Florida that, after Mr. Epstein had fully complied with his obligations under the NPA, the USAO-SDFL affirmatively encouraged alleged victims to pursue prosecution of Mr. Epstein in other districts, in violation of the DOJ's commitment to a \"global\" resolution. See Exhibit 2, at 8-12. The United States Attorney for the Southern District of Florida, along with supervisory and line prosecutors from the USAO-SDFL, corresponded on multiple occasions with, and personally conferred with, alleged victims and their lawyers to entertain discussions about the alleged victims' desire to have Mr. Epstein prosecuted on federal charges. See id. at 9. Further, the Southern District of New York is likely relying upon physical evidence seized in connection with the prior investigation, see Gov't Bail Letter at 6 (discussing \"corroborating evidence,\" including \"contemporaneous notes, messages . . . , and call records\"). In short, there will be evidence that the current New York case is not truly independent of the prior immunized conduct. The evidence will show that Mr. Epstein's reasonable expectation that the NPA would \"resolve globally [Mr. Epstein's] state and federal criminal liability\" in exchange for Mr. Epstein's compliance with the duties and obligations in the NPA - which he fully performed - has been unconstitutionally undermined by the government's efforts to minimize the potential consequences of a CVRA conferral violation (one that neither the government nor defense believes occurred but that was found to have occurred in the CVRA litigation which is pending a decision on remedies) by returning an inextricably intertwined second federal prosecution just as the District Court in Florida is receiving submissions on remedy.",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "8",
|
||||
"position": "footer"
|
||||
},
|
||||
{
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||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000281",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Mr. Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"Department of Justice",
|
||||
"USAO-SDFL"
|
||||
],
|
||||
"locations": [
|
||||
"Florida",
|
||||
"Southern District of Florida",
|
||||
"New York",
|
||||
"Palm Beach"
|
||||
],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"2001-07"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"Case 1:19-cr-00490-RMB",
|
||||
"Document 6",
|
||||
"Case No. 2008-CF-9381AXX",
|
||||
"DOJ-OGR-00000281"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein. The text is printed and there are no visible stamps or handwritten notes. The document is page 8 of 16."
|
||||
}
|
||||
74
results/IMAGES001/DOJ-OGR-00000282.json
Normal file
74
results/IMAGES001/DOJ-OGR-00000282.json
Normal file
@ -0,0 +1,74 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "9",
|
||||
"document_number": "6",
|
||||
"date": "07/11/19",
|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 9 of 16\n\nFinally, the government fails to consider the doctrine of pre-indictment delay, inasmuch as the statute of limitations does not fully define a defendant's rights with respect to delays that occurred prior to the indictment. See generally United States v. Marion, 404 U.S. 307 (1971). Here, the delays of 14 years from the last alleged act and 12 years since Mr. Epstein signed the NPA are extraordinary. If the government is correct that the NPA does not, and never did, preclude a prosecution in this district, then the government will have to explain why it purposefully delayed a prosecution of someone like Mr. Epstein, who registered as a sex offender 10 years ago and was certainly no stranger to law enforcement. There is no legitimate explanation for the delay.\n\nIII. The government fails to meet its burden of proving that no combination of conditions will assure Mr. Epstein's appearance and public safety\n\nAn analysis of the relevant statutory factors and case law supports pretrial release. Even should the Court conclude, despite substantial evidence to the contrary, that the defendant presents a risk of flight, the foregoing combination of conditions virtually guarantees his appearance as required. Crucially, while it is always possible to hypothesize risks, the statutory standard requires only a reasonable assurance that the defendant, if released, will appear. The conditions proposed above, including electronic GPS monitoring, surrender of Mr. Epstein's passport, deregistration and/or grounding of Mr. Epstein's private plane, and a substantial personal bond (including posting of personal residence(s) and/or private jet as security to guarantee appearance) would extinguish any plausible risks. Mr. Epstein's current notoriety minimizes any conceivable risk of flight even further. The location where he could be detained - his residence on East 71st Street in New York has entrances (one on the street, one in the back) that can be easily monitored by video. With all of his financial resources in the United States (other than his Paris residence) and with his New York residence at risk due to the government's forfeiture allegation, Mr. Epstein would be sacrificing virtually everything he has worked for - including any collateral the Court requires he post to secure his appearance - if he were to flee and to disentitle himself to the defense of his property whether it would be at risk to forfeiture or for a bail violation.\n\nTo the extent there is any doubt regarding the proposed conditions, there is tremendous moral suasion provided by the posting of real and personal property of Mr. Epstein's brother, and his close personal friend of decades, who have offered to co-sign a surety bond to ensure Mr. Epstein's appearance in Court as required. Indeed, Mr. Epstein's brother has agreed to pledge his family home, that he shares half the year with his 14-year-old daughter and 17-year-old son, in order to secure the bond. It is particularly telling that Mr. Epstein's brother, his only living immediate family member, as well as his close personal friend, are both willing to guarantee his appearance, notwithstanding the widespread negative publicity of Mr. Epstein that has dominated the news cycle since his arrest.\n\n9\nDOJ-OGR-00000282",
|
||||
"text_blocks": [
|
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|
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|
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|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Finally, the government fails to consider the doctrine of pre-indictment delay, inasmuch as the statute of limitations does not fully define a defendant's rights with respect to delays that occurred prior to the indictment. See generally United States v. Marion, 404 U.S. 307 (1971). Here, the delays of 14 years from the last alleged act and 12 years since Mr. Epstein signed the NPA are extraordinary. If the government is correct that the NPA does not, and never did, preclude a prosecution in this district, then the government will have to explain why it purposefully delayed a prosecution of someone like Mr. Epstein, who registered as a sex offender 10 years ago and was certainly no stranger to law enforcement. There is no legitimate explanation for the delay.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "III. The government fails to meet its burden of proving that no combination of conditions will assure Mr. Epstein's appearance and public safety",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "An analysis of the relevant statutory factors and case law supports pretrial release. Even should the Court conclude, despite substantial evidence to the contrary, that the defendant presents a risk of flight, the foregoing combination of conditions virtually guarantees his appearance as required. Crucially, while it is always possible to hypothesize risks, the statutory standard requires only a reasonable assurance that the defendant, if released, will appear. The conditions proposed above, including electronic GPS monitoring, surrender of Mr. Epstein's passport, deregistration and/or grounding of Mr. Epstein's private plane, and a substantial personal bond (including posting of personal residence(s) and/or private jet as security to guarantee appearance) would extinguish any plausible risks. Mr. Epstein's current notoriety minimizes any conceivable risk of flight even further. The location where he could be detained - his residence on East 71st Street in New York has entrances (one on the street, one in the back) that can be easily monitored by video. With all of his financial resources in the United States (other than his Paris residence) and with his New York residence at risk due to the government's forfeiture allegation, Mr. Epstein would be sacrificing virtually everything he has worked for - including any collateral the Court requires he post to secure his appearance - if he were to flee and to disentitle himself to the defense of his property whether it would be at risk to forfeiture or for a bail violation.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "To the extent there is any doubt regarding the proposed conditions, there is tremendous moral suasion provided by the posting of real and personal property of Mr. Epstein's brother, and his close personal friend of decades, who have offered to co-sign a surety bond to ensure Mr. Epstein's appearance in Court as required. Indeed, Mr. Epstein's brother has agreed to pledge his family home, that he shares half the year with his 14-year-old daughter and 17-year-old son, in order to secure the bond. It is particularly telling that Mr. Epstein's brother, his only living immediate family member, as well as his close personal friend, are both willing to guarantee his appearance, notwithstanding the widespread negative publicity of Mr. Epstein that has dominated the news cycle since his arrest.",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "9",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000282",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Mr. Epstein",
|
||||
"Mr. Epstein's brother",
|
||||
"Mr. Epstein's friend"
|
||||
],
|
||||
"organizations": [
|
||||
"United States Court"
|
||||
],
|
||||
"locations": [
|
||||
"New York",
|
||||
"Paris",
|
||||
"East 71st Street"
|
||||
],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"10 years ago"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"Document 6",
|
||||
"DOJ-OGR-00000282",
|
||||
"404 U.S. 307"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein. The text is printed and there are no visible stamps or handwritten notes. The document is page 9 of 16."
|
||||
}
|
||||
88
results/IMAGES001/DOJ-OGR-00000283.json
Normal file
88
results/IMAGES001/DOJ-OGR-00000283.json
Normal file
@ -0,0 +1,88 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "10",
|
||||
"document_number": "6",
|
||||
"date": "07/11/19",
|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
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|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 10 of 16\n\nTo reiterate, the Bail Reform Act requires pretrial release on the \"least restrictive\" conditions that will assure both appearance and public safety. 18 U.S.C. § 3142(c)(1)(B) (emphasis added). Home confinement monitored by 24-hour private security guards - a lesser restriction than pretrial detention - has proven effective in meeting those goals in many prominent cases prosecuted in our Circuit, including cases against defendants as infamous as Bernie Madoff, Marc Dreier and David Brooks.\n\nTo be clear, defense counsel are fully confident Mr. Epstein will appear as required without resort to this measure. And we understand and appreciate Your Honor's opposition to it. See United States v. Zarrab, No. 15-CR-867, 2016 WL 3681423 (S.D.N.Y. June 16, 2016). Still, Mr. Epstein stands ready and willing to pay for 24-hour armed guards should the Court deem it necessary or appropriate.\n\nMore precisely, we realize that Your Honor objects to the measure as more akin to custody than release, finding it inequitable for wealthier defendants to \"buy their way out\" of jail pending trial. Id. at *2, *9-10, *13 (citation omitted). Nonetheless, a band of other courts in our area have endorsed the procedure,7 and the Second Circuit has affirmed its use.8\n\nFor reasons explained elsewhere, round-the-clock, privately funded security guards will virtually guarantee - not just reasonably assure - Mr. Epstein's presence in the circumstances of this case. Accordingly, and given the division of authority surrounding the practice, we respectfully propose it here as a fallback, asking the Court to revisit its propriety despite the reservations expressed in Zarrab. Those reservations, though admirably motivated and sincerely held, raise substantial equal protection concerns. They impair the statutory right to release on the least restrictive conditions in the circumstances presented - an inherently individualized determination - based largely on socioeconomic status, a suspect if not invidious classification. Avoiding \"inequity and unequal treatment\" rooted in such dubious socioeconomic distinctions - doing \"equal right to the poor\" and \"rich\" alike - are imperatives that run both ways. Id. (bolding deleted) (citation, footnote and internal quotation marks omitted).\n\n7 See, e.g., United States v. Esposito, 354 F. Supp. 3d 354 (S.D.N.Y. 2019); United States v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018); United States v. Seng, No. 15-CR-706, 2017 WL 2693625 (S.D.N.Y. Oct. 23, 2015); United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009); United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009); United States v. Schlegel, No. 06-CR-550, 2008 WL 11338900, at *1 (E.D.N.Y. June 13, 2008), modification denied, 2008 WL 11339654 (E.D.N.Y. July 2, 2008).\n\n8 See United States v. Esposito, 749 F. App'x 20 (2d Cir. 2018); United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007).\n\n10\nDOJ-OGR-00000283",
|
||||
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|
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|
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"content": "To reiterate, the Bail Reform Act requires pretrial release on the \"least restrictive\" conditions that will assure both appearance and public safety. 18 U.S.C. § 3142(c)(1)(B) (emphasis added). Home confinement monitored by 24-hour private security guards - a lesser restriction than pretrial detention - has proven effective in meeting those goals in many prominent cases prosecuted in our Circuit, including cases against defendants as infamous as Bernie Madoff, Marc Dreier and David Brooks.",
|
||||
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|
||||
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|
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|
||||
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||||
"content": "To be clear, defense counsel are fully confident Mr. Epstein will appear as required without resort to this measure. And we understand and appreciate Your Honor's opposition to it. See United States v. Zarrab, No. 15-CR-867, 2016 WL 3681423 (S.D.N.Y. June 16, 2016). Still, Mr. Epstein stands ready and willing to pay for 24-hour armed guards should the Court deem it necessary or appropriate.",
|
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|
||||
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|
||||
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|
||||
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||||
"content": "More precisely, we realize that Your Honor objects to the measure as more akin to custody than release, finding it inequitable for wealthier defendants to \"buy their way out\" of jail pending trial. Id. at *2, *9-10, *13 (citation omitted). Nonetheless, a band of other courts in our area have endorsed the procedure,7 and the Second Circuit has affirmed its use.8",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"content": "For reasons explained elsewhere, round-the-clock, privately funded security guards will virtually guarantee - not just reasonably assure - Mr. Epstein's presence in the circumstances of this case. Accordingly, and given the division of authority surrounding the practice, we respectfully propose it here as a fallback, asking the Court to revisit its propriety despite the reservations expressed in Zarrab. Those reservations, though admirably motivated and sincerely held, raise substantial equal protection concerns. They impair the statutory right to release on the least restrictive conditions in the circumstances presented - an inherently individualized determination - based largely on socioeconomic status, a suspect if not invidious classification. Avoiding \"inequity and unequal treatment\" rooted in such dubious socioeconomic distinctions - doing \"equal right to the poor\" and \"rich\" alike - are imperatives that run both ways. Id. (bolding deleted) (citation, footnote and internal quotation marks omitted).",
|
||||
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|
||||
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|
||||
{
|
||||
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||||
"content": "7 See, e.g., United States v. Esposito, 354 F. Supp. 3d 354 (S.D.N.Y. 2019); United States v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018); United States v. Seng, No. 15-CR-706, 2017 WL 2693625 (S.D.N.Y. Oct. 23, 2015); United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009); United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009); United States v. Schlegel, No. 06-CR-550, 2008 WL 11338900, at *1 (E.D.N.Y. June 13, 2008), modification denied, 2008 WL 11339654 (E.D.N.Y. July 2, 2008).",
|
||||
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||||
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|
||||
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|
||||
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||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"June 16, 2016",
|
||||
"Oct. 23, 2015",
|
||||
"June 13, 2008",
|
||||
"July 2, 2008"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"Document 6",
|
||||
"15-CR-867",
|
||||
"15-CR-706",
|
||||
"06-CR-550"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein, discussing the Bail Reform Act and pretrial release conditions. The text is printed and there are no visible stamps or handwritten notes. The document is page 10 of 16."
|
||||
}
|
||||
76
results/IMAGES001/DOJ-OGR-00000284.json
Normal file
76
results/IMAGES001/DOJ-OGR-00000284.json
Normal file
@ -0,0 +1,76 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "11",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 11 of 16\n\nOther than his 2008 guilty plea predicated on conduct substantially overlapping the same conduct charged here, Mr. Epstein has no criminal history. Congress specifically listed these factors as considerations for the Court, and their absence therefore should weigh in favor of Mr. Epstein's pretrial release. Mr. Epstein comes from a stable and humble family background. All of his remaining family members, his brother, niece, and nephew, reside in the United States. Through his business and the five residences he maintains in the United States, Mr. Epstein employs people, many of whom have been with him for more than a decade, and feels personally responsible for their livelihoods. Mr. Epstein is admittedly wealthy with all of his financial resources (other than his Paris residence) in the United States (including the U.S. Virgin Islands) and will provide the Court with more specific information regarding his assets in a sealed supplemental disclosure prior to the upcoming bail hearing if the Court grants leave to file such a sealed supplement. Mr. Epstein has, to this point, not provided a complete financial disclosure on advice of counsel, motivated by a desire to ensure the accuracy of the information provided to the Court. During the years since his release from incarceration in connection with his Florida guilty plea, Mr. Epstein has been a law-abiding citizen without a single allegation of criminal misconduct during that period and has focused his efforts on business and philanthropy. At the Court's request, Mr. Epstein will provide a sealed list of his philanthropic donations.\n\nCrucially, the government has failed to proffer any evidence that Mr. Epstein has ever indicated an intent to flee from this investigation or any other criminal matter, which several courts have observed is a critical factor in evaluating whether pretrial release is appropriate. See Hanson, 613 F. Supp. 2d at 90 (\"In this case, . . . there is no strong circumstantial evidence indicating that Mrs. Hanson intends to flee the United States\"); United States v. Vortis, 785 F.2d 327 (D.C. Cir.1986) (serious intent to flee is an important factor); United States v. Cole, 715 F. Supp. 677, 679 (E.D. Pa.1988) (defendant told undercover agents he would flee if arrested). In fact, Mr. Epstein has displayed long-term, consistent compliance with Court orders and other legal requirements. As a result of his 2008 guilty plea and corresponding sex-offender designation, Mr. Epstein is required to (1) register for life as a sex offender; (2) regularly verify his address with Virgin Islands, Florida, and New York authorities; (3) annually update his registry photograph; and (4) provide registration authorities with detailed itineraries for all travel (both domestic and international) in which he engages. Mr. Epstein has strictly complied with these requirements, without exception, for approximately ten years.\n\nThe Court inquired about the relationship of the New York State registration classification and the requirements of the Bail Reform Act. And while it is true that the New York Appellate Division held that Mr. Epstein was appropriately classified as a level-three sex offender, this inquiry was entirely backward-looking and based on the allegations contained in a Florida probable cause affidavit describing conduct ending in 2005 that were neither admitted-to nor within the scope of Mr. Epstein's guilty plea. See People v. Epstein, 89 A.D. 3d 570, 571 (N.Y. App. Div. 2011). While Mr. Epstein has made no subsequent attempt to challenge the continuing nature of his designation, his law-abiding behavior for the ensuing decade plus\n\n11\nDOJ-OGR-00000284",
|
||||
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|
||||
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||||
"content": "Other than his 2008 guilty plea predicated on conduct substantially overlapping the same conduct charged here, Mr. Epstein has no criminal history. Congress specifically listed these factors as considerations for the Court, and their absence therefore should weigh in favor of Mr. Epstein's pretrial release. Mr. Epstein comes from a stable and humble family background. All of his remaining family members, his brother, niece, and nephew, reside in the United States. Through his business and the five residences he maintains in the United States, Mr. Epstein employs people, many of whom have been with him for more than a decade, and feels personally responsible for their livelihoods. Mr. Epstein is admittedly wealthy with all of his financial resources (other than his Paris residence) in the United States (including the U.S. Virgin Islands) and will provide the Court with more specific information regarding his assets in a sealed supplemental disclosure prior to the upcoming bail hearing if the Court grants leave to file such a sealed supplement. Mr. Epstein has, to this point, not provided a complete financial disclosure on advice of counsel, motivated by a desire to ensure the accuracy of the information provided to the Court. During the years since his release from incarceration in connection with his Florida guilty plea, Mr. Epstein has been a law-abiding citizen without a single allegation of criminal misconduct during that period and has focused his efforts on business and philanthropy. At the Court's request, Mr. Epstein will provide a sealed list of his philanthropic donations.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Crucially, the government has failed to proffer any evidence that Mr. Epstein has ever indicated an intent to flee from this investigation or any other criminal matter, which several courts have observed is a critical factor in evaluating whether pretrial release is appropriate. See Hanson, 613 F. Supp. 2d at 90 (\"In this case, . . . there is no strong circumstantial evidence indicating that Mrs. Hanson intends to flee the United States\"); United States v. Vortis, 785 F.2d 327 (D.C. Cir.1986) (serious intent to flee is an important factor); United States v. Cole, 715 F. Supp. 677, 679 (E.D. Pa.1988) (defendant told undercover agents he would flee if arrested). In fact, Mr. Epstein has displayed long-term, consistent compliance with Court orders and other legal requirements. As a result of his 2008 guilty plea and corresponding sex-offender designation, Mr. Epstein is required to (1) register for life as a sex offender; (2) regularly verify his address with Virgin Islands, Florida, and New York authorities; (3) annually update his registry photograph; and (4) provide registration authorities with detailed itineraries for all travel (both domestic and international) in which he engages. Mr. Epstein has strictly complied with these requirements, without exception, for approximately ten years.",
|
||||
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|
||||
},
|
||||
{
|
||||
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|
||||
"content": "The Court inquired about the relationship of the New York State registration classification and the requirements of the Bail Reform Act. And while it is true that the New York Appellate Division held that Mr. Epstein was appropriately classified as a level-three sex offender, this inquiry was entirely backward-looking and based on the allegations contained in a Florida probable cause affidavit describing conduct ending in 2005 that were neither admitted-to nor within the scope of Mr. Epstein's guilty plea. See People v. Epstein, 89 A.D. 3d 570, 571 (N.Y. App. Div. 2011). While Mr. Epstein has made no subsequent attempt to challenge the continuing nature of his designation, his law-abiding behavior for the ensuing decade plus",
|
||||
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||||
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|
||||
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||||
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||||
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|
||||
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|
||||
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|
||||
"entities": {
|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
"dates": [
|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
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|
||||
"1:19-cr-00490-RMB",
|
||||
"Document 6",
|
||||
"613 F. Supp. 2d",
|
||||
"785 F.2d 327",
|
||||
"715 F. Supp. 677",
|
||||
"89 A.D. 3d 570"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein, discussing his background, financial resources, and compliance with court orders. The text is printed and there is no handwriting or stamps visible."
|
||||
}
|
||||
83
results/IMAGES001/DOJ-OGR-00000285.json
Normal file
83
results/IMAGES001/DOJ-OGR-00000285.json
Normal file
@ -0,0 +1,83 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "12 of 16",
|
||||
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|
||||
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|
||||
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||||
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||||
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|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 12 of 16\n\nsignificantly undercuts any suggestion of current dangerousness based on any regulatory classification. Moreover, as discussed above, Mr. Epstein's strict compliance with the various monitoring requirements associated with his sex-offender registration actually decrease any danger that he might otherwise pose. It is also worth noting that Mr. Epstein is classified as a tier-one sex offender, the lowest classification available, in the U.S. Virgin Islands, where he maintains his primary residence. The defense respectfully suggests that Mr. Epstein's Virgin Islands designation is more consistent with the circumstances of the actual offenses for which he was convicted, and certainly more consistent with the predictive factor of whether there is a danger of recidivism which the defense contends there is not.\n\nMr. Epstein's financial means and past international travel do not extinguish this Court's congressional mandate to order pretrial release in every case where reasonable conditions can assure the appearance of the defendant as required.9 Indeed, numerous courts have rejected government requests for detention, and instead ordered pretrial release, in cases where the charged defendant was either a non-citizen (unlike Mr. Epstein) or a naturalized citizen with substantial if not weightier contacts with foreign jurisdictions, including the following decisions:\n\n- United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007) (reversing district court order of detention of defendants, who were natives of Indonesia, and ordering release despite defendants' \"strong motive to flee\" because of serious charges and \"strong\" evidence of guilt, despite finding that defendants faced \"lengthy term of incarceration\" if convicted, despite finding defendants possessed \"ample means to finance flight,\" despite finding that defendants \"maintained strong family ties to their native countries as well as personal and professional ties to various locations in Europe and the Middle East,\" and despite finding that defendants \"could, with relatively little disruption, continue to operate their highly lucrative business from any number of overseas locations\");\n\n- United States v. Hansen, 108 F. App'x 331 (6th Cir. 2004) (affirming district court order of pretrial release of defendant, a resident and citizen of Denmark-from where defendant could not be extradited-charged with bulk cash smuggling and forfeiture, noting that the\n\n9 This Court's opinion in Zarrab stands only for the proposition that wealthy defendants should not be provided an unfair advantage. It does not, of course, suggest that wealthy defendants should bear a special disadvantage. The facts supporting the Court's ruling of pretrial detention in Zarrab are easily distinguishable. The present case does not have national security implications, Mr. Epstein is a United States citizen (and does not possess any dual citizenship), the only foreign country in which Mr. Epstein maintains a residence (France) has an extradition treaty with the United States, Mr. Epstein's assets are almost all located in the United States (with the exception of his Paris residence), and Mr. Epstein has provided only truthful information to Pretrial Services.\n\n12\nDOJ-OGR-00000285",
|
||||
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||||
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|
||||
"position": "header"
|
||||
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|
||||
{
|
||||
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|
||||
"content": "significantly undercuts any suggestion of current dangerousness based on any regulatory classification. Moreover, as discussed above, Mr. Epstein's strict compliance with the various monitoring requirements associated with his sex-offender registration actually decrease any danger that he might otherwise pose. It is also worth noting that Mr. Epstein is classified as a tier-one sex offender, the lowest classification available, in the U.S. Virgin Islands, where he maintains his primary residence. The defense respectfully suggests that Mr. Epstein's Virgin Islands designation is more consistent with the circumstances of the actual offenses for which he was convicted, and certainly more consistent with the predictive factor of whether there is a danger of recidivism which the defense contends there is not.",
|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Mr. Epstein's financial means and past international travel do not extinguish this Court's congressional mandate to order pretrial release in every case where reasonable conditions can assure the appearance of the defendant as required.9 Indeed, numerous courts have rejected government requests for detention, and instead ordered pretrial release, in cases where the charged defendant was either a non-citizen (unlike Mr. Epstein) or a naturalized citizen with substantial if not weightier contacts with foreign jurisdictions, including the following decisions:",
|
||||
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|
||||
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|
||||
{
|
||||
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|
||||
"content": "- United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007) (reversing district court order of detention of defendants, who were natives of Indonesia, and ordering release despite defendants' \"strong motive to flee\" because of serious charges and \"strong\" evidence of guilt, despite finding that defendants faced \"lengthy term of incarceration\" if convicted, despite finding defendants possessed \"ample means to finance flight,\" despite finding that defendants \"maintained strong family ties to their native countries as well as personal and professional ties to various locations in Europe and the Middle East,\" and despite finding that defendants \"could, with relatively little disruption, continue to operate their highly lucrative business from any number of overseas locations\");",
|
||||
"position": "middle"
|
||||
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|
||||
{
|
||||
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|
||||
"content": "- United States v. Hansen, 108 F. App'x 331 (6th Cir. 2004) (affirming district court order of pretrial release of defendant, a resident and citizen of Denmark-from where defendant could not be extradited-charged with bulk cash smuggling and forfeiture, noting that the",
|
||||
"position": "middle"
|
||||
},
|
||||
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|
||||
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|
||||
"content": "9 This Court's opinion in Zarrab stands only for the proposition that wealthy defendants should not be provided an unfair advantage. It does not, of course, suggest that wealthy defendants should bear a special disadvantage. The facts supporting the Court's ruling of pretrial detention in Zarrab are easily distinguishable. The present case does not have national security implications, Mr. Epstein is a United States citizen (and does not possess any dual citizenship), the only foreign country in which Mr. Epstein maintains a residence (France) has an extradition treaty with the United States, Mr. Epstein's assets are almost all located in the United States (with the exception of his Paris residence), and Mr. Epstein has provided only truthful information to Pretrial Services.",
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein. The text is printed and there are no visible stamps or handwritten notes. The document is page 12 of 16."
|
||||
}
|
||||
83
results/IMAGES001/DOJ-OGR-00000286.json
Normal file
83
results/IMAGES001/DOJ-OGR-00000286.json
Normal file
@ -0,0 +1,83 @@
|
||||
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|
||||
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|
||||
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|
||||
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||||
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||||
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||||
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||||
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||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 13 of 16\n\n\"bail statute does not . . . require that foreign defendants be detained simply because their return cannot be guaranteed through extradition\");\n\nUnited States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004) (ordering release of defendant, an Israeli national who had resided in South Africa for the 18 years preceding his arrest when he landed in Colorado for a family ski trip based on allegations he violated the Export Administration Act and the International Economic Emergency Powers Act by acquiring products capable of triggering nuclear weapons and exported them to Pakistan, despite defendant's lack of any ties to the United States, despite finding that defendant had \"no ties to the United States or the Washington, D.C. area,\" despite finding that \"no evidence [was] presented establishing that Defendant has ever lived in this country, owned property here, or that he has any family or community ties in the United States,\" despite finding that defendant \"was only in this country in order to participate in a ski vacation with his wife and daughter,\" and despite finding that \"the weight of the evidence against Defendant is substantial\");\n\nUnited States v. Hanson, 613 F. Supp. 2d 85 (D.D.C. 2009) (ordering release of defendant, a naturalized citizen of the United States, despite finding defendant \"has strong ties to [her home country of] China,\" finding that the defendant owned property in China, that the defendant spent almost all of her ten years of marriage living abroad with her husband, that during 2008 the defendant spent only 22 days in the United States, that the charges against the defendant (violations of International Emergency Economic Powers Act and the Export Administration Regulations) \"were serious and carried a potential for a significant period of incarceration\" and that the \"government has strong evidence against\" the defendant \"including her own statement to investigators that she smuggled the UAV autopilot components out of the United States and knew there were licensing requirements for such items\").\n\nThe fact that the government will potentially seek a significant sentence if Mr. Epstein is convicted on all counts similarly does not preclude pretrial release in this case - several courts have ordered pretrial release despite finding that the defendant faced serious charges carrying significant potential sentences. See, e.g., Sabhnani, 493 F.3d 63 (reversing district court order of detention despite finding that defendants, natives of Indonesia, faced \"lengthy term of incarceration\" and \"strong\" evidence of guilt existed); Karni, 298 F. Supp. 2d 129 (ordering release of defendant, an Israeli national who had resided in South Africa for the 18 years preceding his arrest, despite finding that \"the weight of the evidence against Defendant is substantial\"); Hanson, 613 F. Supp. 2d 85 (noting that charges \"were serious and carried a potential for a significant period of incarceration\" and that the \"government has strong evidence against\" the defendant \"including her own statement to investigators that she smuggled the UAV autopilot components out of the United States and knew there were licensing requirements for such items\"). As the government concedes, the increases in sentencing exposure enacted after\n13\nDOJ-OGR-00000286",
|
||||
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||||
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|
||||
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|
||||
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|
||||
{
|
||||
"type": "printed",
|
||||
"content": "United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004) (ordering release of defendant, an Israeli national who had resided in South Africa for the 18 years preceding his arrest when he landed in Colorado for a family ski trip based on allegations he violated the Export Administration Act and the International Economic Emergency Powers Act by acquiring products capable of triggering nuclear weapons and exported them to Pakistan, despite defendant's lack of any ties to the United States, despite finding that defendant had \"no ties to the United States or the Washington, D.C. area,\" despite finding that \"no evidence [was] presented establishing that Defendant has ever lived in this country, owned property here, or that he has any family or community ties in the United States,\" despite finding that defendant \"was only in this country in order to participate in a ski vacation with his wife and daughter,\" and despite finding that \"the weight of the evidence against Defendant is substantial\");",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "United States v. Hanson, 613 F. Supp. 2d 85 (D.D.C. 2009) (ordering release of defendant, a naturalized citizen of the United States, despite finding defendant \"has strong ties to [her home country of] China,\" finding that the defendant owned property in China, that the defendant spent almost all of her ten years of marriage living abroad with her husband, that during 2008 the defendant spent only 22 days in the United States, that the charges against the defendant (violations of International Emergency Economic Powers Act and the Export Administration Regulations) \"were serious and carried a potential for a significant period of incarceration\" and that the \"government has strong evidence against\" the defendant \"including her own statement to investigators that she smuggled the UAV autopilot components out of the United States and knew there were licensing requirements for such items\").",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "The fact that the government will potentially seek a significant sentence if Mr. Epstein is convicted on all counts similarly does not preclude pretrial release in this case - several courts have ordered pretrial release despite finding that the defendant faced serious charges carrying significant potential sentences. See, e.g., Sabhnani, 493 F.3d 63 (reversing district court order of detention despite finding that defendants, natives of Indonesia, faced \"lengthy term of incarceration\" and \"strong\" evidence of guilt existed); Karni, 298 F. Supp. 2d 129 (ordering release of defendant, an Israeli national who had resided in South Africa for the 18 years preceding his arrest, despite finding that \"the weight of the evidence against Defendant is substantial\"); Hanson, 613 F. Supp. 2d 85 (noting that charges \"were serious and carried a potential for a significant period of incarceration\" and that the \"government has strong evidence against\" the defendant \"including her own statement to investigators that she smuggled the UAV autopilot components out of the United States and knew there were licensing requirements for such items\"). As the government concedes, the increases in sentencing exposure enacted after",
|
||||
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|
||||
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|
||||
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||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"entities": {
|
||||
"people": [
|
||||
"Epstein",
|
||||
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|
||||
"Hanson",
|
||||
"Sabhnani"
|
||||
],
|
||||
"organizations": [
|
||||
"United States"
|
||||
],
|
||||
"locations": [
|
||||
"South Africa",
|
||||
"Colorado",
|
||||
"Pakistan",
|
||||
"United States",
|
||||
"Washington, D.C.",
|
||||
"China",
|
||||
"Indonesia"
|
||||
],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"2004",
|
||||
"2009",
|
||||
"2008"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"Document 6",
|
||||
"298 F. Supp. 2d 129",
|
||||
"613 F. Supp. 2d 85",
|
||||
"493 F.3d 63",
|
||||
"DOJ-OGR-00000286"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein. The text is printed and there are no visible stamps or handwritten notes. The document is page 13 of 16."
|
||||
}
|
||||
82
results/IMAGES001/DOJ-OGR-00000287.json
Normal file
82
results/IMAGES001/DOJ-OGR-00000287.json
Normal file
@ -0,0 +1,82 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "14 of 16",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 14 of 16\n\nthe alleged conduct at issue here do not apply retroactively to Mr. Epstein's case (including a maximum sentence of life imprisonment and a mandatory minimum sentence of 10 years). Mr. Epstein would, moreover, be subject to prosecution if he fled, which he now knows carries a maximum penalty of up to 10 additional years of imprisonment, 18 U.S.C. § 3146(b)(l)(A)(l), and/or the real risk of an enhanced sentence by the Court in this matter if not acquitted.\n\nIt must further be emphasized that the allegations outlined within the indictment are just that - allegations - and the defendant anticipates substantial factual and legal challenges to the government case. For one thing, Epstein has potent legal defenses to prosecution under 18 U.S.C. § 1591, the sex trafficking statute driving the pending indictment. We front and briefly outline one of those defenses for the limited purpose of seeking bail. We will amplify it later, along with various other arguments, in full-blown dismissal motions.\n\nSection 1591 was passed as part of the Trafficking Victims Protection Act of 2000 (\"TVPA\"), Pub. L. No. 106-386, 114 Stat. 1464 (October 28, 2000). In enacting the TVPA, Congress recognized that human trafficking, particularly of women and children in the sex industry, \"is a modern form of slavery, and it is the largest manifestation of slavery today.\" 22 U.S.C. § 7101(b)(1); see also id. at § 7101(b)(2), (4). \"The TVPA criminalizes and attempts to prevent slavery, involuntary servitude, and human trafficking for commercial gain.\" United States v. Evans, 476 F.3d 1176, 1179 (11th Cir. 2007). Importantly, \"the entire language and design of the statute as a whole indicates that it is meant to punish those who are the providers or pimps of children, not the purchasers or the johns.\" Fierro v. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3 (S.D.N.Y. July 2, 2012) (quoting United States v. Bonestroo, No. 11-CR-40016, 2012 WL 13704, at *4 (D.S.D. Jan. 4, 2012)) (emphasis added). In Fierro, the district court found § 1591 inapplicable to consumers or purchasers of sex acts. Here, the principal conduct underlying the indictment is Mr. Epstein's payment of money for massages that purportedly escalated to alleged sex acts. Mr. Epstein's conduct, however, is akin to consumer or purchaser behavior and should be outside the ambit of 18 U.S.C. § 1591. See Fierro, 2012 WL 13042630, at *4 (\"[T]he TVPA is inapplicable to individual purchasers of sex from trafficking victims...\").10\n\n10 While Fierro represents the law in this district, Mr. Epstein notes that there is a division of authority on the scope of § 1591. See United States v. Jungers, 702 F.3d 1066, 1068 (8th Cir. 2013). The defense respectfully submits that the Fierro court's approach to this issue is more persuasive and more consistent with the Congressional purpose to target commercial sex trafficking.\n\n14\nDOJ-OGR-00000287",
|
||||
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||||
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||||
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||||
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|
||||
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||||
"content": "the alleged conduct at issue here do not apply retroactively to Mr. Epstein's case (including a maximum sentence of life imprisonment and a mandatory minimum sentence of 10 years). Mr. Epstein would, moreover, be subject to prosecution if he fled, which he now knows carries a maximum penalty of up to 10 additional years of imprisonment, 18 U.S.C. § 3146(b)(l)(A)(l), and/or the real risk of an enhanced sentence by the Court in this matter if not acquitted.",
|
||||
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|
||||
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|
||||
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|
||||
"type": "printed",
|
||||
"content": "It must further be emphasized that the allegations outlined within the indictment are just that - allegations - and the defendant anticipates substantial factual and legal challenges to the government case. For one thing, Epstein has potent legal defenses to prosecution under 18 U.S.C. § 1591, the sex trafficking statute driving the pending indictment. We front and briefly outline one of those defenses for the limited purpose of seeking bail. We will amplify it later, along with various other arguments, in full-blown dismissal motions.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Section 1591 was passed as part of the Trafficking Victims Protection Act of 2000 (\"TVPA\"), Pub. L. No. 106-386, 114 Stat. 1464 (October 28, 2000). In enacting the TVPA, Congress recognized that human trafficking, particularly of women and children in the sex industry, \"is a modern form of slavery, and it is the largest manifestation of slavery today.\" 22 U.S.C. § 7101(b)(1); see also id. at § 7101(b)(2), (4). \"The TVPA criminalizes and attempts to prevent slavery, involuntary servitude, and human trafficking for commercial gain.\" United States v. Evans, 476 F.3d 1176, 1179 (11th Cir. 2007). Importantly, \"the entire language and design of the statute as a whole indicates that it is meant to punish those who are the providers or pimps of children, not the purchasers or the johns.\" Fierro v. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3 (S.D.N.Y. July 2, 2012) (quoting United States v. Bonestroo, No. 11-CR-40016, 2012 WL 13704, at *4 (D.S.D. Jan. 4, 2012)) (emphasis added). In Fierro, the district court found § 1591 inapplicable to consumers or purchasers of sex acts. Here, the principal conduct underlying the indictment is Mr. Epstein's payment of money for massages that purportedly escalated to alleged sex acts. Mr. Epstein's conduct, however, is akin to consumer or purchaser behavior and should be outside the ambit of 18 U.S.C. § 1591. See Fierro, 2012 WL 13042630, at *4 (\"[T]he TVPA is inapplicable to individual purchasers of sex from trafficking victims...\").10",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
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|
||||
"content": "10 While Fierro represents the law in this district, Mr. Epstein notes that there is a division of authority on the scope of § 1591. See United States v. Jungers, 702 F.3d 1066, 1068 (8th Cir. 2013). The defense respectfully submits that the Fierro court's approach to this issue is more persuasive and more consistent with the Congressional purpose to target commercial sex trafficking.",
|
||||
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|
||||
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||||
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||||
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||||
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||||
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||||
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||||
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|
||||
}
|
||||
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|
||||
"entities": {
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
],
|
||||
"dates": [
|
||||
"October 28, 2000",
|
||||
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|
||||
"Jan. 4, 2012",
|
||||
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|
||||
],
|
||||
"reference_numbers": [
|
||||
"Case 1:19-cr-00490-RMB",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"Pub. L. No. 106-386",
|
||||
"114 Stat. 1464",
|
||||
"No. 11-CV8573",
|
||||
"No. 11-CR-40016",
|
||||
"702 F.3d 1066",
|
||||
"476 F.3d 1176",
|
||||
"DOJ-OGR-00000287"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein, discussing legal defenses and challenges to the indictment under 18 U.S.C. § 1591. The text is printed and there are no visible stamps or handwritten notes."
|
||||
}
|
||||
90
results/IMAGES001/DOJ-OGR-00000288.json
Normal file
90
results/IMAGES001/DOJ-OGR-00000288.json
Normal file
@ -0,0 +1,90 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
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||||
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||||
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||||
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||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 15 of 16\n\nIV. Sixth Amendment\n\nFinally, in a case such as this one, which will likely involve voluminous discovery and is predicated on events allegedly occurring 14 or more years ago, it is critical to counsel's ability to provide effective assistance, as well as the defendant's ability to meaningfully contribute to his defense, that Mr. Epstein be permitted pretrial release. The Sixth Amendment \"does not provide merely that a defense shall be made for the accused; it grants to the accused personally the right to make his defense. It is the accused, not counsel, who must be 'informed of the nature and cause of the accusation,' and who must be 'confronted with the witnesses against him,' and who must be accorded 'compulsory process for obtaining witnesses in his favor.'\" Faretta v. California, 422 U.S. 806, 819 (1975). Given the unique circumstances of this case, Mr. Epstein's exercise of these important Constitutional rights would be materially impaired by his pretrial detention.\n\nV. Conclusion\n\nWherefore, for all of the foregoing reasons, Mr. Epstein respectfully submits that his conduct over the past 14 years proves that he poses no risk of flight or threat to the safety of the community. Even if the Court should have concerns to the contrary, there clearly exist a combination of conditions that would be sufficient to assure his presence as required and/or the safety of the community, including but not limited to some or all of the conditions proposed supra, or any other conditions the Court deems necessary and appropriate.\n\nYours truly,\n\nReid Weingarten\nSteptoe & Johnson, LLP (NYC)\n1114 Avenue of the Americas\nNew York, NY 10036\n(202)-506-3900\nFax: (212)-506-3950\nrweingarten@steptoe.com\n\nMartin G. Weinberg (application for admission pro hac vice forthcoming)\nMartin G. Weinberg, P.C.\n20 Park Plaza, Suite 1000\nBoston, MA 02116\n(617) 227-3700\nFax: (617) 338-9538\nowlmgw@att.net\n\n15\n\nDOJ-OGR-00000288",
|
||||
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||||
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||||
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|
||||
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|
||||
},
|
||||
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|
||||
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|
||||
"content": "Finally, in a case such as this one, which will likely involve voluminous discovery and is predicated on events allegedly occurring 14 or more years ago, it is critical to counsel's ability to provide effective assistance, as well as the defendant's ability to meaningfully contribute to his defense, that Mr. Epstein be permitted pretrial release. The Sixth Amendment \"does not provide merely that a defense shall be made for the accused; it grants to the accused personally the right to make his defense. It is the accused, not counsel, who must be 'informed of the nature and cause of the accusation,' and who must be 'confronted with the witnesses against him,' and who must be accorded 'compulsory process for obtaining witnesses in his favor.'\" Faretta v. California, 422 U.S. 806, 819 (1975). Given the unique circumstances of this case, Mr. Epstein's exercise of these important Constitutional rights would be materially impaired by his pretrial detention.",
|
||||
"position": "middle"
|
||||
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||||
{
|
||||
"type": "printed",
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||||
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|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Wherefore, for all of the foregoing reasons, Mr. Epstein respectfully submits that his conduct over the past 14 years proves that he poses no risk of flight or threat to the safety of the community. Even if the Court should have concerns to the contrary, there clearly exist a combination of conditions that would be sufficient to assure his presence as required and/or the safety of the community, including but not limited to some or all of the conditions proposed supra, or any other conditions the Court deems necessary and appropriate.",
|
||||
"position": "middle"
|
||||
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||||
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|
||||
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||||
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||||
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|
||||
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||||
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|
||||
"content": "Reid Weingarten\nSteptoe & Johnson, LLP (NYC)\n1114 Avenue of the Americas\nNew York, NY 10036\n(202)-506-3900\nFax: (212)-506-3950\nrweingarten@steptoe.com",
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||||
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||||
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||||
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|
||||
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||||
"content": "Martin G. Weinberg (application for admission pro hac vice forthcoming)\nMartin G. Weinberg, P.C.\n20 Park Plaza, Suite 1000\nBoston, MA 02116\n(617) 227-3700\nFax: (617) 338-9538\nowlmgw@att.net",
|
||||
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|
||||
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||||
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||||
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||||
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|
||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"additional_notes": "The document appears to be a court filing related to the case of Mr. Epstein. The text is well-formatted and printed. There are no visible redactions or damage."
|
||||
}
|
||||
53
results/IMAGES001/DOJ-OGR-00000289.json
Normal file
53
results/IMAGES001/DOJ-OGR-00000289.json
Normal file
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|
||||
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|
||||
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||||
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||||
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||||
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||||
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||||
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||||
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|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 16 of 16\nMarc Allan Fernich\nLaw Office of Marc Fernich\n810 Seventh Ave\nSuite 620\nNew York, NY 10019\n(212) 446-2346\nFax: (212) 446 2330\nmaf@fernichlaw.com\n\n\n\n\n\n\n\n\n\n\n\n\n\n16\nDOJ-OGR-00000289",
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||||
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||||
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|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Marc Allan Fernich"
|
||||
],
|
||||
"organizations": [
|
||||
"Law Office of Marc Fernich"
|
||||
],
|
||||
"locations": [
|
||||
"New York"
|
||||
],
|
||||
"dates": [
|
||||
"07/11/19"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"Document 6",
|
||||
"DOJ-OGR-00000289"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing with a letterhead or contact information for Marc Allan Fernich. The quality is clear, and there are no visible redactions or damage."
|
||||
}
|
||||
44
results/IMAGES001/DOJ-OGR-00000290.json
Normal file
44
results/IMAGES001/DOJ-OGR-00000290.json
Normal file
@ -0,0 +1,44 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "1",
|
||||
"document_number": "6-1",
|
||||
"date": "07/11/19",
|
||||
"document_type": "Exhibit",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 1 of 15 EXHIBIT 1 DOJ-OGR-00000290",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "EXHIBIT 1",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000290",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [],
|
||||
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|
||||
"DOJ"
|
||||
],
|
||||
"locations": [],
|
||||
"dates": [
|
||||
"07/11/19"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"6-1",
|
||||
"DOJ-OGR-00000290"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing with a clear header and footer. The main content is labeled as 'EXHIBIT 1'. There are no visible redactions or damage."
|
||||
}
|
||||
108
results/IMAGES001/DOJ-OGR-00000291.json
Normal file
108
results/IMAGES001/DOJ-OGR-00000291.json
Normal file
@ -0,0 +1,108 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "2 of 15",
|
||||
"document_number": "6-1",
|
||||
"date": "07/11/19",
|
||||
"document_type": "Non-Prosecution Agreement",
|
||||
"has_handwriting": true,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 2 of 15\nCase 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 2 of 15\nNPA\nIN RE:\nINVESTIGATION OF\nJEFFREY EPSTEIN\nNON-PROSECUTION AGREEMENT\nIT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the \"State Attorney's Office\") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter 'Epstein');\nIT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in violation of Florida Statutes Section 796.07;\nIT APPEARING that the United States Attorney's Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein's background and any offenses that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007, including:\n(1) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b); all in violation of Title 18, United States Code, Section 371;\n(2) knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e);\n(3) using a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2;\n(4) traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation\nPage 1 of 7\nDOJ-OGR-00000291",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 2 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 2 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "NPA",
|
||||
"position": "margin"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "IN RE:\nINVESTIGATION OF\nJEFFREY EPSTEIN\nNON-PROSECUTION AGREEMENT",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "IT APPEARING that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the \"State Attorney's Office\") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter 'Epstein');",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in violation of Florida Statutes Section 796.07;",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "IT APPEARING that the United States Attorney's Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein's background and any offenses that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007, including:",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "(1) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b); all in violation of Title 18, United States Code, Section 371;",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "(2) knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e);",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "(3) using a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2;",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "(4) traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Page 1 of 7",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000291",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Jeffrey Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"City of Palm Beach Police Department",
|
||||
"State Attorney's Office",
|
||||
"United States Attorney's Office",
|
||||
"Federal Bureau of Investigation"
|
||||
],
|
||||
"locations": [
|
||||
"Palm Beach",
|
||||
"Palm Beach County",
|
||||
"United States"
|
||||
],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"02/10/2016",
|
||||
"2001",
|
||||
"September 2007"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"9:08-cv-80736-KAM",
|
||||
"Document 6-1",
|
||||
"Document 361-62",
|
||||
"DOJ-OGR-00000291"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a Non-Prosecution Agreement related to the investigation of Jeffrey Epstein. It includes details about the charges and investigations conducted by various law enforcement agencies."
|
||||
}
|
||||
83
results/IMAGES001/DOJ-OGR-00000292.json
Normal file
83
results/IMAGES001/DOJ-OGR-00000292.json
Normal file
@ -0,0 +1,83 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "3",
|
||||
"document_number": "6-1",
|
||||
"date": "07/11/19",
|
||||
"document_type": "Court Document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 3 of 15\nCase 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 3 of 15\n\nof Title 18, United States Code, Section 2423(b); and\n(5) knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18, United States Code, Sections 1591(a)(1) and 2; and\n\nIT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that, in exchange for the benefits provided by this agreement, he agrees to comply with its terms, including undertaking certain actions with the State Attorney's Office;\n\nIT APPEARING, after an investigation of the offenses and Epstein's background by both State and Federal law enforcement agencies, and after due consultation with the State Attorney's Office, that the interests of the United States, the State of Florida, and the Defendant will be served by the following procedure;\n\nTHEREFOR, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below.\n\nIf the United States Attorney should determine, based on reliable evidence, that, during the period of the Agreement, Epstein willfully violated any of the conditions of this Agreement, then the United States Attorney may, within ninety (90) days following the expiration of the term of home confinement discussed below, provide Epstein with timely notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its prosecution on any offense within sixty (60) days' of giving notice of the violation. Any notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the United States learning of facts which may provide a basis for a determination of a breach of the Agreement.\n\nAfter timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed.\n\nPage 2 of 7\n\nDOJ-OGR-00000292",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 3 of 15\nCase 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 3 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "of Title 18, United States Code, Section 2423(b); and\n(5) knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18, United States Code, Sections 1591(a)(1) and 2; and",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that, in exchange for the benefits provided by this agreement, he agrees to comply with its terms, including undertaking certain actions with the State Attorney's Office;",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "IT APPEARING, after an investigation of the offenses and Epstein's background by both State and Federal law enforcement agencies, and after due consultation with the State Attorney's Office, that the interests of the United States, the State of Florida, and the Defendant will be served by the following procedure;",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "THEREFOR, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "If the United States Attorney should determine, based on reliable evidence, that, during the period of the Agreement, Epstein willfully violated any of the conditions of this Agreement, then the United States Attorney may, within ninety (90) days following the expiration of the term of home confinement discussed below, provide Epstein with timely notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its prosecution on any offense within sixty (60) days' of giving notice of the violation. Any notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the United States learning of facts which may provide a basis for a determination of a breach of the Agreement.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed.",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Page 2 of 7",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000292",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Epstein",
|
||||
"R. Alexander Acosta"
|
||||
],
|
||||
"organizations": [
|
||||
"State Attorney's Office",
|
||||
"Federal Bureau of Investigation",
|
||||
"United States Attorney's Office"
|
||||
],
|
||||
"locations": [
|
||||
"Florida",
|
||||
"United States"
|
||||
],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"02/10/2016"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"9:08-cv-80736-KAM",
|
||||
"DOJ-OGR-00000292"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court document related to a case involving Epstein. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
|
||||
}
|
||||
92
results/IMAGES001/DOJ-OGR-00000293.json
Normal file
92
results/IMAGES001/DOJ-OGR-00000293.json
Normal file
@ -0,0 +1,92 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "4",
|
||||
"document_number": "6-1",
|
||||
"date": "07/11/19",
|
||||
"document_type": "Court Document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 4 of 15 Case 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 4 of 15 Terms of the Agreement: 1. Epstein shall plead guilty (not nolo contendere) to the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging one (1) count of solicitation of prostitution, in violation of Fl. Stat. § 796.07. In addition, Epstein shall plead guilty to an Information filed by the State Attorney's Office charging Epstein with an offense that requires him to register as a sex offender, that is, the solicitation of minors to engage in prostitution, in violation of Florida Statutes Section 796.03; 2. Epstein shall make a binding recommendation that the Court impose a thirty (30) month sentence to be divided as follows: (a) Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6) months in county jail for all charges, without any opportunity for withholding adjudication or sentencing, and without probation or community control in lieu of imprisonment; and (b) Epstein shall be sentenced to a term of twelve (12) months of community control consecutive to his two terms in county jail as described in Term 2(a), supra. 3. This agreement is contingent upon a Judge of the 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorney's Office and Epstein, the details of which are set forth in this agreement. 4. The terms contained in paragraphs 1 and 2, supra, do not foreclose Epstein and the State Attorney's Office from agreeing to recommend any additional charge(s) or any additional term(s) of probation and/or incarceration. 5. Epstein shall waive all challenges to the Information filed by the State Attorney's Office and shall waive the right to appeal his conviction and sentence, except a sentence that exceeds what is set forth in paragraph (2), supra. 6. Epstein shall provide to the U.S. Attorney's Office copies of all Page 3 of 7 DOJ-OGR-00000293",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 4 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 4 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Terms of the Agreement:",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "1. Epstein shall plead guilty (not nolo contendere) to the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging one (1) count of solicitation of prostitution, in violation of Fl. Stat. § 796.07. In addition, Epstein shall plead guilty to an Information filed by the State Attorney's Office charging Epstein with an offense that requires him to register as a sex offender, that is, the solicitation of minors to engage in prostitution, in violation of Florida Statutes Section 796.03;",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "2. Epstein shall make a binding recommendation that the Court impose a thirty (30) month sentence to be divided as follows: (a) Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6) months in county jail for all charges, without any opportunity for withholding adjudication or sentencing, and without probation or community control in lieu of imprisonment; and (b) Epstein shall be sentenced to a term of twelve (12) months of community control consecutive to his two terms in county jail as described in Term 2(a), supra.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "3. This agreement is contingent upon a Judge of the 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorney's Office and Epstein, the details of which are set forth in this agreement.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "4. The terms contained in paragraphs 1 and 2, supra, do not foreclose Epstein and the State Attorney's Office from agreeing to recommend any additional charge(s) or any additional term(s) of probation and/or incarceration.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "5. Epstein shall waive all challenges to the Information filed by the State Attorney's Office and shall waive the right to appeal his conviction and sentence, except a sentence that exceeds what is set forth in paragraph (2), supra.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "6. Epstein shall provide to the U.S. Attorney's Office copies of all",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Page 3 of 7",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000293",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"State Attorney's Office",
|
||||
"U.S. Attorney's Office"
|
||||
],
|
||||
"locations": [
|
||||
"Palm Beach County",
|
||||
"Florida"
|
||||
],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"02/10/2016"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"9:08-cv-80736-KAM",
|
||||
"2006-cf-009495AXXXMB",
|
||||
"DOJ-OGR-00000293"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to Jeffrey Epstein's case, outlining the terms of his plea agreement. The document is printed and contains no handwritten text or stamps."
|
||||
}
|
||||
88
results/IMAGES001/DOJ-OGR-00000294.json
Normal file
88
results/IMAGES001/DOJ-OGR-00000294.json
Normal file
@ -0,0 +1,88 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "5",
|
||||
"document_number": "6-1",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 5 of 15\nCase 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 5 of 15\n\nproposed agreements with the State Attorney's Office prior to entering into those agreements.\n\n7. The United States shall provide Epstein's attorneys with a list of individuals whom it has identified as victims, as defined in 18 U.S.C. § 2255, after Epstein has signed this agreement and been sentenced. Upon the execution of this agreement, the United States, in consultation with and subject to the good faith approval of Epstein's counsel, shall select an attorney representative for these persons, who shall be paid for by Epstein. Epstein's counsel may contact the identified individuals through that representative.\n\n8. If any of the individuals referred to in paragraph (7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between the identified individual and Epstein, so long as the identified individual elects to proceed exclusively under 18 U.S.C. § 2255, and agrees to waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein's signature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability.\n\n9. Epstein's signature on this agreement also is not to be construed as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whose name does not appear on the list provided by the United States.\n\n10. Except as to those individuals who elect to proceed exclusively under 18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's signature on this agreement, nor its terms, nor any resulting waivers or settlements by Epstein are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list provided by the United States.\n\n11. Epstein shall use his best efforts to enter his guilty plea and be\n\nPage 4 of 7\n\nDOJ-OGR-00000294",
|
||||
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|
||||
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|
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
},
|
||||
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|
||||
"type": "printed",
|
||||
"content": "proposed agreements with the State Attorney's Office prior to entering into those agreements.",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"content": "7. The United States shall provide Epstein's attorneys with a list of individuals whom it has identified as victims, as defined in 18 U.S.C. § 2255, after Epstein has signed this agreement and been sentenced. Upon the execution of this agreement, the United States, in consultation with and subject to the good faith approval of Epstein's counsel, shall select an attorney representative for these persons, who shall be paid for by Epstein. Epstein's counsel may contact the identified individuals through that representative.",
|
||||
"position": "main body"
|
||||
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|
||||
{
|
||||
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|
||||
"content": "8. If any of the individuals referred to in paragraph (7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between the identified individual and Epstein, so long as the identified individual elects to proceed exclusively under 18 U.S.C. § 2255, and agrees to waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein's signature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability.",
|
||||
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|
||||
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|
||||
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||||
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|
||||
"content": "9. Epstein's signature on this agreement also is not to be construed as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whose name does not appear on the list provided by the United States.",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"content": "10. Except as to those individuals who elect to proceed exclusively under 18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's signature on this agreement, nor its terms, nor any resulting waivers or settlements by Epstein are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list provided by the United States.",
|
||||
"position": "main body"
|
||||
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|
||||
{
|
||||
"type": "printed",
|
||||
"content": "11. Epstein shall use his best efforts to enter his guilty plea and be",
|
||||
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|
||||
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|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Page 4 of 7",
|
||||
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|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000294",
|
||||
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|
||||
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|
||||
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|
||||
"entities": {
|
||||
"people": [
|
||||
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|
||||
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|
||||
"organizations": [
|
||||
"United States District Court for the Southern District of Florida",
|
||||
"State Attorney's Office"
|
||||
],
|
||||
"locations": [
|
||||
"Florida"
|
||||
],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"02/10/2016"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"9:08-cv-80736-KAM",
|
||||
"Document 6-1",
|
||||
"Document 361-62",
|
||||
"18 U.S.C. § 2255",
|
||||
"DOJ-OGR-00000294"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to Jeffrey Epstein's case. It contains legal language and references to specific laws and court documents. The text is mostly printed, with no visible handwriting or stamps. The document is likely a scanned or photocopied version of the original."
|
||||
}
|
||||
87
results/IMAGES001/DOJ-OGR-00000295.json
Normal file
87
results/IMAGES001/DOJ-OGR-00000295.json
Normal file
@ -0,0 +1,87 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "6",
|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 6 of 15\nCase 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 6 of 15\n\nsentenced not later than October 26, 2007. The United States has no objection to Epstein self-reporting to begin serving his sentence not later than January 4, 2008.\n\n12. Epstein agrees that he will not be afforded any benefits with respect to gain time, other than the rights, opportunities, and benefits as any other inmate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration.\n\n13. The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure.\n\nEpstein understands that the United States Attorney has no authority to require the State Attorney's Office to abide by any terms of this agreement. Epstein understands that it is his obligation to undertake discussions with the State Attorney's Office and to use his best efforts to ensure compliance with these procedures, which compliance will be necessary to satisfy the United States' interest. Epstein also understands that it is his obligation to use his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding recommendation regarding the sentence to be imposed, and understands that the failure to do so will be a breach of the agreement.\n\nIn consideration of Epstein's agreement to plead guilty and to provide compensation in the manner described above, if Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. Further, upon execution of this agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of this agreement. The defendant likewise agrees to withdraw his pending motion to intervene and to quash certain grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence requested by or directly related to the grand jury subpoenas that have been issued, and including certain computer equipment, until all of the terms of this agreement have been satisfied. Upon the successful completion of the terms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn.\n\nPage 5 of 7\n\nDOJ-OGR-00000295",
|
||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
"content": "12. Epstein agrees that he will not be afforded any benefits with respect to gain time, other than the rights, opportunities, and benefits as any other inmate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration.",
|
||||
"position": "main"
|
||||
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|
||||
{
|
||||
"type": "printed",
|
||||
"content": "13. The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure.",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"content": "Epstein understands that the United States Attorney has no authority to require the State Attorney's Office to abide by any terms of this agreement. Epstein understands that it is his obligation to undertake discussions with the State Attorney's Office and to use his best efforts to ensure compliance with these procedures, which compliance will be necessary to satisfy the United States' interest. Epstein also understands that it is his obligation to use his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding recommendation regarding the sentence to be imposed, and understands that the failure to do so will be a breach of the agreement.",
|
||||
"position": "main"
|
||||
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|
||||
{
|
||||
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|
||||
"content": "In consideration of Epstein's agreement to plead guilty and to provide compensation in the manner described above, if Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. Further, upon execution of this agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of this agreement. The defendant likewise agrees to withdraw his pending motion to intervene and to quash certain grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence requested by or directly related to the grand jury subpoenas that have been issued, and including certain computer equipment, until all of the terms of this agreement have been satisfied. Upon the successful completion of the terms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn.",
|
||||
"position": "main"
|
||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"entities": {
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"organizations": [
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"dates": [
|
||||
"October 26, 2007",
|
||||
"January 4, 2008",
|
||||
"07/11/19",
|
||||
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|
||||
],
|
||||
"reference_numbers": [
|
||||
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|
||||
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|
||||
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|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to Jeffrey Epstein's case. It contains details about the agreement between Epstein and the United States Attorney's Office, including terms related to his sentencing, incarceration, and potential co-conspirators. The document is heavily redacted in some versions but this image is clear."
|
||||
}
|
||||
71
results/IMAGES001/DOJ-OGR-00000296.json
Normal file
71
results/IMAGES001/DOJ-OGR-00000296.json
Normal file
@ -0,0 +1,71 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "7",
|
||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 7 of 15\nCase 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 7 of 15\n\nBy signing this agreement, Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses.\n\nBy signing this agreement, Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution. Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution, as provided for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement as to those offenses that were the subject of the grand jury's investigation. Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees and consents that, if a prosecution against him is instituted for any offense that was the subject of the grand jury's investigation, it may be by way of an Information signed and filed by the United States Attorney, and hereby waives his right to be indicted by a grand jury as to any such offense.\n\n///\n///\n///\n\nPage 6 of 7\n\nDOJ-OGR-0000296",
|
||||
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||||
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||||
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|
||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
"type": "printed",
|
||||
"content": "By signing this agreement, Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses.",
|
||||
"position": "body"
|
||||
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|
||||
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|
||||
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|
||||
"content": "By signing this agreement, Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution. Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution, as provided for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement as to those offenses that were the subject of the grand jury's investigation. Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees and consents that, if a prosecution against him is instituted for any offense that was the subject of the grand jury's investigation, it may be by way of an Information signed and filed by the United States Attorney, and hereby waives his right to be indicted by a grand jury as to any such offense.",
|
||||
"position": "body"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "///\n///\n///",
|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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||||
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|
||||
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||||
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|
||||
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|
||||
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||||
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|
||||
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|
||||
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||||
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||||
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||||
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||||
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||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
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|
||||
"DOJ-OGR-0000296"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to a case involving Jeffrey Epstein. The text is mostly printed, with some placeholder text ('///') in the body. There are no visible stamps or handwritten annotations."
|
||||
}
|
||||
97
results/IMAGES001/DOJ-OGR-00000297.json
Normal file
97
results/IMAGES001/DOJ-OGR-00000297.json
Normal file
@ -0,0 +1,97 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "8",
|
||||
"document_number": "6-1",
|
||||
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|
||||
"document_type": "Non-Prosecution Agreement",
|
||||
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|
||||
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|
||||
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|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 8 of 15 Case 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 8 of 15 By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non-Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: _____________ By: ______________________________________ A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY Dated: 9/24/07 ______________________________________ JEFFREY EPSTEIN Dated: _____________ GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated: _____________ LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 DOJ-OGR-00000297",
|
||||
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|
||||
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|
||||
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||||
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||||
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||||
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||||
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||||
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||||
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|
||||
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|
||||
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|
||||
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|
||||
"content": "By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non-Prosecution Agreement and agrees to comply with them.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
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|
||||
"content": "R. ALEXANDER ACOSTA UNITED STATES ATTORNEY",
|
||||
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|
||||
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|
||||
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|
||||
"type": "printed",
|
||||
"content": "Dated: _____________ By: ______________________________________",
|
||||
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|
||||
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|
||||
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|
||||
"type": "printed",
|
||||
"content": "A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "9/24/07",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "signature",
|
||||
"content": "JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Page 7 of 7",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000297",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Jeffrey Epstein",
|
||||
"R. Alexander Acosta",
|
||||
"A. Marie Villafana",
|
||||
"Gerald Lefcourt",
|
||||
"Lilly Ann Sanchez"
|
||||
],
|
||||
"organizations": [
|
||||
"United States Attorney"
|
||||
],
|
||||
"locations": [],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"02/10/2016",
|
||||
"9/24/07"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"9:08-cv-80736-KAM",
|
||||
"DOJ-OGR-00000297"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a Non-Prosecution Agreement between Jeffrey Epstein and the United States Attorney's Office. The document is signed by Jeffrey Epstein and his attorneys, Gerald Lefcourt and Lilly Ann Sanchez. The agreement is dated 9/24/07."
|
||||
}
|
||||
119
results/IMAGES001/DOJ-OGR-00000298.json
Normal file
119
results/IMAGES001/DOJ-OGR-00000298.json
Normal file
@ -0,0 +1,119 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "9",
|
||||
"document_number": "6-1",
|
||||
"date": "07/11/19",
|
||||
"document_type": "Non-Prosecution Agreement",
|
||||
"has_handwriting": true,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 9 of 15\nCase 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 9 of 15\n\nBy signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non-Prosecution Agreement and agrees to comply with them.\n\nR. ALEXANDER ACOSTA\nUNITED STATES ATTORNEY\n\nDated: ____________________\nBy: A. MARIE VILLAFANA\nASSISTANT U.S. ATTORNEY\n\nDated: ____________________\n\nDated: 9/24/07\nJEFFREY EPSTEIN\n\nGERALD LEFCOURT, ESQ.\nCOUNSEL TO JEFFREY EPSTEIN\n\nDated: ____________________\nLILLY ANN SANCHEZ, ESQ.\nATTORNEY FOR JEFFREY EPSTEIN\n\nPage 7 of 7\n\nDOJ-OGR-00000298",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 9 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 9 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non-Prosecution Agreement and agrees to comply with them.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "R. ALEXANDER ACOSTA\nUNITED STATES ATTORNEY",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: ____________________",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "By: A. MARIE VILLAFANA\nASSISTANT U.S. ATTORNEY",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: ____________________",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "9/24/07",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "signature",
|
||||
"content": "Jeffrey Epstein's signature",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "GERALD LEFCOURT, ESQ.\nCOUNSEL TO JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "signature",
|
||||
"content": "Gerald Lefcourt's signature",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: ____________________",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "LILLY ANN SANCHEZ, ESQ.\nATTORNEY FOR JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Page 7 of 7",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000298",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Jeffrey Epstein",
|
||||
"R. Alexander Acosta",
|
||||
"A. Marie Villafana",
|
||||
"Gerald Lefcourt",
|
||||
"Lilly Ann Sanchez"
|
||||
],
|
||||
"organizations": [
|
||||
"United States Attorney's Office"
|
||||
],
|
||||
"locations": [
|
||||
"Florida"
|
||||
],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"02/10/2016",
|
||||
"9/24/07"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"9:08-cv-80736-KAM",
|
||||
"DOJ-OGR-00000298"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a Non-Prosecution Agreement between Jeffrey Epstein and the United States Attorney's Office. The document is signed by Jeffrey Epstein and his attorneys, Gerald Lefcourt and Lilly Ann Sanchez. The agreement is dated 9/24/07."
|
||||
}
|
||||
99
results/IMAGES001/DOJ-OGR-00000299.json
Normal file
99
results/IMAGES001/DOJ-OGR-00000299.json
Normal file
@ -0,0 +1,99 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "10",
|
||||
"document_number": "6-1",
|
||||
"date": "07/11/19",
|
||||
"document_type": "Non-Prosecution Agreement",
|
||||
"has_handwriting": true,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 10 of 15\nCase 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 10 of 15\n\nBy signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non-Prosecution Agreement and agrees to comply with them.\n\nR. ALEXANDER ACOSTA\nUNITED STATES ATTORNEY\n\nDated: _______________________ By: _______________________\nA. MARIE VILLAFANA\nASSISTANT U.S. ATTORNEY\n\nDated: _______________________ JEFFREY EPSTEIN\n\nDated: _______________________ GERALD LEFCOURT, ESQ.\nCOUNSEL TO JEFFREY EPSTEIN\n\nDated: 9-24-07 LILLY ANN SANSBEEZ, ESQ.\nATTORNEY FOR JEFFREY EPSTEIN\n\nPage 7 of 7\n\nDOJ-OGR-00000299",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 10 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 10 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non-Prosecution Agreement and agrees to comply with them.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "R. ALEXANDER ACOSTA\nUNITED STATES ATTORNEY",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: _______________________ By: _______________________",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "A. MARIE VILLAFANA\nASSISTANT U.S. ATTORNEY",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: _______________________ JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: _______________________ GERALD LEFCOURT, ESQ.\nCOUNSEL TO JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "9-24-07",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "LILLY ANN SANSBEEZ, ESQ.\nATTORNEY FOR JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Page 7 of 7",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000299",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"R. Alexander Acosta",
|
||||
"A. Marie Villafana",
|
||||
"Jeffrey Epstein",
|
||||
"Gerald Lefcourt",
|
||||
"Lilly Ann Sansbeez"
|
||||
],
|
||||
"organizations": [
|
||||
"United States Attorney's Office"
|
||||
],
|
||||
"locations": [],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"02/10/2016",
|
||||
"9-24-07"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"9:08-cv-80736-KAM",
|
||||
"Document 6-1",
|
||||
"Document 361-62",
|
||||
"DOJ-OGR-00000299"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a Non-Prosecution Agreement between Jeffrey Epstein and the United States Attorney's Office. The document is signed by multiple parties, including Epstein's attorneys. The date '9-24-07' is handwritten next to one of the signatures."
|
||||
}
|
||||
79
results/IMAGES001/DOJ-OGR-00000300.json
Normal file
79
results/IMAGES001/DOJ-OGR-00000300.json
Normal file
@ -0,0 +1,79 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "11",
|
||||
"document_number": "6-1",
|
||||
"date": "07/11/19",
|
||||
"document_type": "Court Document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 11 of 15\nCase 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 11 of 15\n\nIN RE:\nINVESTIGATION OF\nJEFFREY EPSTEIN\n\nADDENDUM TO THE NON-PROSECUTION AGREEMENT\n\nIT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 of the Non-Prosecution Agreement (hereinafter \"paragraph 7\"), that agreement is modified as follows:\n\n7A. The United States has the right to assign to an independent third-party the responsibility for consulting with and, subject to the good faith approval of Epstein's counsel, selecting the attorney representative for the individuals identified under the Agreement. If the United States elects to assign this responsibility to an independent third-party, both the United States and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent third-party prior to the final designation of the attorney representative.\n\n7B. The parties will jointly prepare a short written submission to the independent third-party regarding the role of the attorney representative and regarding Epstein's Agreement to pay such attorney representative his or her regular customary hourly rate for representing such victims subject to the provisions of paragraph C, infra.\n\n7C. Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney representative selected by the independent third party. This provision, however, shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, if after consideration of potential settlements, an attorney representative elects to file a contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney representative, shall cease.\n\nDOJ-OGR-00000300",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 11 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 11 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "IN RE:\nINVESTIGATION OF\nJEFFREY EPSTEIN",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "ADDENDUM TO THE NON-PROSECUTION AGREEMENT",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 of the Non-Prosecution Agreement (hereinafter \"paragraph 7\"), that agreement is modified as follows:",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "7A. The United States has the right to assign to an independent third-party the responsibility for consulting with and, subject to the good faith approval of Epstein's counsel, selecting the attorney representative for the individuals identified under the Agreement. If the United States elects to assign this responsibility to an independent third-party, both the United States and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent third-party prior to the final designation of the attorney representative.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "7B. The parties will jointly prepare a short written submission to the independent third-party regarding the role of the attorney representative and regarding Epstein's Agreement to pay such attorney representative his or her regular customary hourly rate for representing such victims subject to the provisions of paragraph C, infra.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "7C. Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney representative selected by the independent third party. This provision, however, shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, if after consideration of potential settlements, an attorney representative elects to file a contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney representative, shall cease.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000300",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Jeffrey Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"United States"
|
||||
],
|
||||
"locations": [],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"02/10/2016"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"9:08-cv-80736-KAM",
|
||||
"Document 6-1",
|
||||
"Document 361-62",
|
||||
"DOJ-OGR-00000300"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the investigation of Jeffrey Epstein. It is a modification to a non-prosecution agreement and outlines the terms of the agreement regarding the representation of victims. The document is well-formatted and legible."
|
||||
}
|
||||
74
results/IMAGES001/DOJ-OGR-00000301.json
Normal file
74
results/IMAGES001/DOJ-OGR-00000301.json
Normal file
@ -0,0 +1,74 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "12",
|
||||
"document_number": "6-1",
|
||||
"date": "07/11/19",
|
||||
"document_type": "Addendum",
|
||||
"has_handwriting": true,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 12 of 15 Case 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 12 of 15 By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Non-Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY Dated: 1/29/19 JEFFREY EPSTEIN Dated: GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated: LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN DOJ-OGR-00000301",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 12 of 15 Case 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 12 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Non-Prosecution Agreement and agrees to comply with them.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "R. ALEXANDER ACOSTA UNITED STATES ATTORNEY",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: By: A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "1/29/19",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated: LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000301",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Jeffrey Epstein",
|
||||
"R. Alexander Acosta",
|
||||
"A. Marie Villafana",
|
||||
"Gerald Lefcourt",
|
||||
"Lilly Ann Sanchez"
|
||||
],
|
||||
"organizations": [
|
||||
"United States Attorney"
|
||||
],
|
||||
"locations": [],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"02/10/2016",
|
||||
"1/29/19"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"9:08-cv-80736-KAM",
|
||||
"6-1",
|
||||
"361-62",
|
||||
"DOJ-OGR-00000301"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a scanned copy of a signed addendum related to a legal case involving Jeffrey Epstein. The document contains both printed and handwritten text, with signatures present. There are no visible redactions or significant damage."
|
||||
}
|
||||
99
results/IMAGES001/DOJ-OGR-00000302.json
Normal file
99
results/IMAGES001/DOJ-OGR-00000302.json
Normal file
@ -0,0 +1,99 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "13",
|
||||
"document_number": "6-1",
|
||||
"date": "07/11/19",
|
||||
"document_type": "Court Document",
|
||||
"has_handwriting": true,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 13 of 15 Case 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 13 of 15 By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Non-Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: __________________ By: A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY Dated: __________________ JEFFREY EPSTEIN ________________________ Dated: 10/29/07 GERALD LEFCOURT ESQ. COUNSEL TO JEFFREY EPSTEIN ________________________ Dated: __________________ LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN DOJ-OGR-00000302",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 13 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 13 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Non-Prosecution Agreement and agrees to comply with them.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "R. ALEXANDER ACOSTA UNITED STATES ATTORNEY",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: __________________ By: A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: __________________ JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "10/29/07",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "Jeffrey Epstein",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "Gerald Lefcourt",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "GERALD LEFCOURT ESQ. COUNSEL TO JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: __________________ LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000302",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Jeffrey Epstein",
|
||||
"R. Alexander Acosta",
|
||||
"A. Marie Villafana",
|
||||
"Gerald Lefcourt",
|
||||
"Lilly Ann Sanchez"
|
||||
],
|
||||
"organizations": [
|
||||
"United States Attorney"
|
||||
],
|
||||
"locations": [],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"02/10/2016",
|
||||
"10/29/07"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"9:08-cv-80736-KAM",
|
||||
"6-1",
|
||||
"361-62",
|
||||
"DOJ-OGR-00000302"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to Jeffrey Epstein's case. It contains signatures and dates, indicating its authenticity. The document is mostly printed, with some handwritten elements."
|
||||
}
|
||||
84
results/IMAGES001/DOJ-OGR-00000303.json
Normal file
84
results/IMAGES001/DOJ-OGR-00000303.json
Normal file
@ -0,0 +1,84 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "14 of 15",
|
||||
"document_number": "6-1",
|
||||
"date": "07/11/19",
|
||||
"document_type": "Addendum to Non-Prosecution Agreement",
|
||||
"has_handwriting": true,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 14 of 15\nCase 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 14 of 15\n\nBy signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Non-Prosecution Agreement and agrees to comply with them.\n\nR. ALEXANDER ACOSTA\nUNITED STATES ATTORNEY\n\nDated: ____________________\nBy: A. MARIE VILLAFANA\nASSISTANT U.S. ATTORNEY\n\nDated: ____________________\nJEFFREY EPSTEIN\n\nDated: ____________________\nGERALD LECOURT, ESQ.\nCOUNSEL TO JEFFREY EPSTEIN\n\nDated: 10-29-07\nLILLY ANN SANCHEZ, ESQ.\nATTORNEY FOR JEFFREY EPSTEIN\n\nDOJ-OGR-00000303",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 14 of 15\nCase 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 14 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Non-Prosecution Agreement and agrees to comply with them.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "R. ALEXANDER ACOSTA\nUNITED STATES ATTORNEY",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: ____________________\nBy: A. MARIE VILLAFANA\nASSISTANT U.S. ATTORNEY",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: ____________________\nJEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: ____________________\nGERALD LECOURT, ESQ.\nCOUNSEL TO JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "10-29-07",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dated: 10-29-07\nLILLY ANN SANCHEZ, ESQ.\nATTORNEY FOR JEFFREY EPSTEIN",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000303",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"R. Alexander Acosta",
|
||||
"A. Marie Villafana",
|
||||
"Jeffrey Epstein",
|
||||
"Gerald Lefcourt",
|
||||
"Lilly Ann Sanchez"
|
||||
],
|
||||
"organizations": [
|
||||
"United States Attorney's Office"
|
||||
],
|
||||
"locations": [],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"02/10/2016",
|
||||
"10-29-07"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"9:08-cv-80736-KAM",
|
||||
"6-1",
|
||||
"361-62",
|
||||
"DOJ-OGR-00000303"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document is a scanned copy of an addendum to a non-prosecution agreement signed by Jeffrey Epstein. The document contains signatures and dates, indicating that it is a legally binding agreement. The quality of the scan is good, and the text is legible."
|
||||
}
|
||||
84
results/IMAGES001/DOJ-OGR-00000304.json
Normal file
84
results/IMAGES001/DOJ-OGR-00000304.json
Normal file
@ -0,0 +1,84 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "15",
|
||||
"document_number": "6-1",
|
||||
"date": "07/11/19",
|
||||
"document_type": "Affirmation",
|
||||
"has_handwriting": true,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 15 of 15\nCase 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 15 of 15\nDec-07-07 04:55pm From-Fowler White Burnett 3057898201 T-056 P.003/004 F-076\nAffirmation\nI, Jeffrey E. Epstein do hereby re-affirm the Non-Prosecution Agreement and Addendum to same dated October 30, 2007.\n12/7/07 Date\nJeffrey E. Epstein\nDOJ-OGR-00000304",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 6-1 Filed 07/11/19 Page 15 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 9:08-cv-80736-KAM Document 361-62 Entered on FLSD Docket 02/10/2016 Page 15 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Dec-07-07 04:55pm From-Fowler White Burnett 3057898201 T-056 P.003/004 F-076",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Affirmation",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "I, Jeffrey E. Epstein do hereby re-affirm the Non-Prosecution Agreement and Addendum to same dated October 30, 2007.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "handwritten",
|
||||
"content": "12/7/07",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "signature",
|
||||
"content": "Jeffrey E. Epstein",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000304",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Jeffrey E. Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"Fowler White Burnett",
|
||||
"DOJ"
|
||||
],
|
||||
"locations": [
|
||||
"FLSD"
|
||||
],
|
||||
"dates": [
|
||||
"07/11/19",
|
||||
"02/10/2016",
|
||||
"Dec-07-07",
|
||||
"12/7/07",
|
||||
"October 30, 2007"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"9:08-cv-80736-KAM",
|
||||
"Document 6-1",
|
||||
"Document 361-62",
|
||||
"3057898201",
|
||||
"T-056",
|
||||
"P.003/004",
|
||||
"F-076",
|
||||
"DOJ-OGR-00000304"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a faxed affirmation signed by Jeffrey E. Epstein. The document is related to a court case and includes a reference to a non-prosecution agreement."
|
||||
}
|
||||
44
results/IMAGES001/DOJ-OGR-00000305.json
Normal file
44
results/IMAGES001/DOJ-OGR-00000305.json
Normal file
@ -0,0 +1,44 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "1",
|
||||
"document_number": "6-2",
|
||||
"date": "07/11/19",
|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 1:19-cr-00490-RMB Document 6-2 Filed 07/11/19 Page 1 of 15 EXHIBIT 2 DOJ-OGR-00000305",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 1:19-cr-00490-RMB Document 6-2 Filed 07/11/19 Page 1 of 15",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "EXHIBIT 2",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000305",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [],
|
||||
"organizations": [
|
||||
"DOJ"
|
||||
],
|
||||
"locations": [],
|
||||
"dates": [
|
||||
"07/11/19"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"1:19-cr-00490-RMB",
|
||||
"6-2",
|
||||
"DOJ-OGR-00000305"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing with a clear header and footer. The main content is labeled 'EXHIBIT 2'."
|
||||
}
|
||||
86
results/IMAGES001/DOJ-OGR-00000306.json
Normal file
86
results/IMAGES001/DOJ-OGR-00000306.json
Normal file
@ -0,0 +1,86 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "2",
|
||||
"document_number": "209",
|
||||
"date": "07/08/2019",
|
||||
"document_type": "Court Document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 9:08-cv-80736 Document 209 Entered on Filed 07/08/2019 Page 2 of 20\nUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA\nCASE NO. 08-80736-CIV-MARRA/JOHNSON\nJANE DOE #1 AND JANE DOE #2,\nPetitioners,\nvs.\nUNITED STATES,\nRespondent.\n\nUNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION\nThe United States hereby requests that this Court enter an order dismissing these proceedings and the Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771 (DE 1, the \"Petition\"), through which Petitioners Jane Doe #1 and Jane Doe #2 have advanced claims pursuant to the Crime Victims' Rights Act (\"CVRA\"), for lack of subject matter jurisdiction.1 This Court lacks subject matter jurisdiction over the Petition because\n1 See, e.g., Grupo Dataflux v. Atlas Global Group, L.P., 541 U.S. 567, 571 (2004) (\"Challenges to subject-matter jurisdiction can of course be raised at any time prior to final judgment.\"); United States v. Giraldo-Prado, 150 F.3d 1328, 1329 (11th Cir. 1998) (recognizing that \"a party may raise jurisdiction at any time during the pendency of the proceedings\"); Harrell & Sumner Contracting Co. v. Peabody Petersen Co., 546 F.2d 1227, 1229 (5th Cir. 1977) (\"[U]nder Rule 12(h)(3), Fed.R.Civ.P., the defense of lack of subject matter jurisdiction may be raised at any time by motion of a party or otherwise.\"); see also Fed. R. Civ. P. 12(h)(3). In the present motion, the United States seeks dismissal of Petitioners' claims based on both a legal and factual challenge to the Court's subject matter jurisdiction. This Court may properly consider and weigh evidence beyond Petitioners' allegations when evaluating such a challenge to the Court's subject matter jurisdiction:\nFactual attacks [on a Court's subject matter jurisdiction] . . . \"challenge subject matter jurisdiction in fact, irrespective of the pleadings.\" In resolving a factual attack, the district court \"may consider extrinsic evidence such as testimony and affidavits.\" Since such a motion implicates the fundamental question of a trial court's jurisdiction,\n1",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "CASE NO. 08-80736-CIV-MARRA/JOHNSON",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "JANE DOE #1 AND JANE DOE #2,\nPetitioners,\nvs.\nUNITED STATES,\nRespondent.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "UNITED STATES' SEALED MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "The United States hereby requests that this Court enter an order dismissing these proceedings and the Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771 (DE 1, the \"Petition\"), through which Petitioners Jane Doe #1 and Jane Doe #2 have advanced claims pursuant to the Crime Victims' Rights Act (\"CVRA\"), for lack of subject matter jurisdiction.1 This Court lacks subject matter jurisdiction over the Petition because",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "1 See, e.g., Grupo Dataflux v. Atlas Global Group, L.P., 541 U.S. 567, 571 (2004) (\"Challenges to subject-matter jurisdiction can of course be raised at any time prior to final judgment.\"); United States v. Giraldo-Prado, 150 F.3d 1328, 1329 (11th Cir. 1998) (recognizing that \"a party may raise jurisdiction at any time during the pendency of the proceedings\"); Harrell & Sumner Contracting Co. v. Peabody Petersen Co., 546 F.2d 1227, 1229 (5th Cir. 1977) (\"[U]nder Rule 12(h)(3), Fed.R.Civ.P., the defense of lack of subject matter jurisdiction may be raised at any time by motion of a party or otherwise.\"); see also Fed. R. Civ. P. 12(h)(3). In the present motion, the United States seeks dismissal of Petitioners' claims based on both a legal and factual challenge to the Court's subject matter jurisdiction. This Court may properly consider and weigh evidence beyond Petitioners' allegations when evaluating such a challenge to the Court's subject matter jurisdiction:",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Factual attacks [on a Court's subject matter jurisdiction] . . . \"challenge subject matter jurisdiction in fact, irrespective of the pleadings.\" In resolving a factual attack, the district court \"may consider extrinsic evidence such as testimony and affidavits.\" Since such a motion implicates the fundamental question of a trial court's jurisdiction,",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "1",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000306",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Jane Doe #1",
|
||||
"Jane Doe #2"
|
||||
],
|
||||
"organizations": [
|
||||
"United States District Court",
|
||||
"United States"
|
||||
],
|
||||
"locations": [
|
||||
"Southern District of Florida"
|
||||
],
|
||||
"dates": [
|
||||
"07/08/2019"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"08-80736-CIV-MARRA/JOHNSON",
|
||||
"9:08-cv-80736",
|
||||
"209",
|
||||
"DE 1",
|
||||
"18 U.S.C. Section 3771",
|
||||
"541 U.S. 567",
|
||||
"150 F.3d 1328",
|
||||
"546 F.2d 1227",
|
||||
"DOJ-OGR-00000306"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing with a clear and legible format. There are no visible redactions or damage to the document."
|
||||
}
|
||||
96
results/IMAGES001/DOJ-OGR-00000307.json
Normal file
96
results/IMAGES001/DOJ-OGR-00000307.json
Normal file
@ -0,0 +1,96 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "3",
|
||||
"document_number": "9:08-cv-01389-KAM Document 209 Filed 07/06/2019 Page 3 of 20",
|
||||
"date": "07/06/2019",
|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Petitioners lack Article III standing and because the claims raised by Petitioners in these proceedings are not constitutionally ripe.\n\nI. The Claims Raised in the Petition Must Be Dismissed for Lack of Subject Matter Jurisdiction Because the Petitioners Lack Standing to Bring Those Claims.\n\nThese proceedings pursuant to the CVRA must be dismissed for lack of subject matter jurisdiction because Petitioners lack standing to pursue the remedies that they are seeking for alleged CVRA violations. As the Supreme Court has explained,\n\nto satisfy Article III's standing requirements, a plaintiff must show (1) it has suffered an \"injury in fact\" that is (a) concrete and particularized and (b) actual or imminent, not conjectural or hypothetical; (2) the injury is fairly traceable to the challenged action of the defendant; and (3) it is likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision.\n\nFriends of the Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167, 180-81 (2000); see also, e.g., Young Apartments, Inc. v. Town of Jupiter, 529 F.3d 1027, 1038 (11th Cir. 2008) (quoting Harris v. Evans, 20 F.3d 1118, 1121 (11th Cir. 1994) (en banc)). Moreover, \"a plaintiff must demonstrate standing separately for each form of relief sought.\" Friends of the Earth, 528 U.S. at 185.\n\nHere, the record incontrovertibly demonstrates that Petitioners cannot satisfy the third prong of the standing test, and the Petition and these proceedings must accordingly be dismissed for lack of subject matter jurisdiction.2 E.g., Florida Wildlife Federation, Inc. v. South Florida\n\ncourt's jurisdiction, a \"trial court is free to weigh the evidence and satisfy itself as to the existence of its power to hear the case\" without presuming the truthfulness of the plaintiff's allegations.\n\nMakro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) (\"[W]e determine whether this lawsuit survives the government's factual attack [on subject matter jurisdiction] by looking to matters outside the pleadings, and we do not accord any presumptive truthfulness to the allegations in the complaint.\"); Scarfo v. Ginsberg, 175 F.3d 957, 960-61 (11th Cir. 1999).\n\n2 Although Petitioners also fail to satisfy the first and second prongs of the standing test,",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Petitioners lack Article III standing and because the claims raised by Petitioners in these proceedings are not constitutionally ripe.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "I. The Claims Raised in the Petition Must Be Dismissed for Lack of Subject Matter Jurisdiction Because the Petitioners Lack Standing to Bring Those Claims.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "These proceedings pursuant to the CVRA must be dismissed for lack of subject matter jurisdiction because Petitioners lack standing to pursue the remedies that they are seeking for alleged CVRA violations. As the Supreme Court has explained,",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "to satisfy Article III's standing requirements, a plaintiff must show (1) it has suffered an \"injury in fact\" that is (a) concrete and particularized and (b) actual or imminent, not conjectural or hypothetical; (2) the injury is fairly traceable to the challenged action of the defendant; and (3) it is likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167, 180-81 (2000); see also, e.g., Young Apartments, Inc. v. Town of Jupiter, 529 F.3d 1027, 1038 (11th Cir. 2008) (quoting Harris v. Evans, 20 F.3d 1118, 1121 (11th Cir. 1994) (en banc)). Moreover, \"a plaintiff must demonstrate standing separately for each form of relief sought.\" Friends of the Earth, 528 U.S. at 185.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Here, the record incontrovertibly demonstrates that Petitioners cannot satisfy the third prong of the standing test, and the Petition and these proceedings must accordingly be dismissed for lack of subject matter jurisdiction.2 E.g., Florida Wildlife Federation, Inc. v. South Florida",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "court's jurisdiction, a \"trial court is free to weigh the evidence and satisfy itself as to the existence of its power to hear the case\" without presuming the truthfulness of the plaintiff's allegations.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Makro Capital of America, Inc. v. UBS AG, 543 F.3d 1254, 1258 (11th Cir. 2008) (citations omitted); see also, e.g., McMaster v. United States, 177 F.3d 936, 940 (11th Cir. 1999) (\"[W]e determine whether this lawsuit survives the government's factual attack [on subject matter jurisdiction] by looking to matters outside the pleadings, and we do not accord any presumptive truthfulness to the allegations in the complaint.\"); Scarfo v. Ginsberg, 175 F.3d 957, 960-61 (11th Cir. 1999).",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "2 Although Petitioners also fail to satisfy the first and second prongs of the standing test,",
|
||||
"position": "bottom"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [],
|
||||
"organizations": [
|
||||
"Friends of the Earth, Inc.",
|
||||
"Laidlaw Environmental Services (TOC), Inc.",
|
||||
"Young Apartments, Inc.",
|
||||
"Town of Jupiter",
|
||||
"Makro Capital of America, Inc.",
|
||||
"UBS AG",
|
||||
"Florida Wildlife Federation, Inc.",
|
||||
"South Florida",
|
||||
"McMaster",
|
||||
"United States",
|
||||
"Scarfo",
|
||||
"Ginsberg"
|
||||
],
|
||||
"locations": [
|
||||
"Jupiter"
|
||||
],
|
||||
"dates": [
|
||||
"2000",
|
||||
"2008",
|
||||
"1994",
|
||||
"07/06/2019",
|
||||
"1999"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"9:08-cv-01389-KAM",
|
||||
"Document 209",
|
||||
"528 U.S. 167",
|
||||
"529 F.3d 1027",
|
||||
"20 F.3d 1118",
|
||||
"543 F.3d 1254",
|
||||
"177 F.3d 936",
|
||||
"175 F.3d 957"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to a case involving the Crime Victims' Rights Act (CVRA). The text is well-formatted and printed, with no visible handwriting or stamps. The document includes citations to various court cases and legal references."
|
||||
}
|
||||
70
results/IMAGES001/DOJ-OGR-00000308.json
Normal file
70
results/IMAGES001/DOJ-OGR-00000308.json
Normal file
@ -0,0 +1,70 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "4",
|
||||
"document_number": "9:08-cv-80736-KAM",
|
||||
"date": "07/09/2019",
|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 9:08-cv-80736-KAM Document 209 Entered on FLSD Docket 07/09/2019 Page 4 of 20\n\nWater Management Dist., 647 F.3d 1296, 1302 (11th Cir. 2011) (“If at any point in the litigation the plaintiff ceases to meet all three requirements for constitutional standing, the case no longer presents a live case or controversy, and the federal court must dismiss the case for lack of subject matter jurisdiction.”); Phoenix of Broward, Inc. v. McDonald’s Corp., 489 F.3d 1156, 1161 (11th Cir. 2007) (“[T]he issue of constitutional standing is jurisdictional . . .”); National Parks Conservation Ass’n v. Norton, 324 F.3d 1229, 1242 (11th Cir. 2003) (“[B]ecause the constitutional standing doctrine stems directly from Article III’s ‘case or controversy’ requirement, this issue implicates our subject matter jurisdiction, and accordingly must be addressed as a threshold matter regardless of whether it is raised by the parties.”) (citation omitted).\n\nIn these proceedings, the only identified legal relief that Petitioners have sought pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney’s Office for the Southern District of Florida (“USAO-SDFL”). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners seek “is to invalidate the non-prosecution agreement”). But even assuming arguendo that Petitioners’ rights under the CVRA were violated when Epstein and the USAO-SDFL entered into the Non-Prosecution Agreement, constitutional due process guarantees do not allow either the Non-Prosecution Agreement – which by its terms induced Epstein to, inter alia, plead guilty to state criminal charges and serve an 18-month sentence of state incarceration3 – or the governmental\n\nthis Court need not reach or address those issues because an analysis of the third prong of the standing test incontrovertibly establishes the Petitioners’ lack of standing. Nonetheless, the circumstances which demonstrate Petitioners’ lack of a concrete injury traceable to government conduct are explored infra in Section II of this memorandum, which addresses how Petitioners’ claims and these proceedings lack constitutional ripeness.\n\n3 See also July 11, 2008 Hr’g Tr. at 20-21 (Petitioners’ acknowledgement that Epstein’s reliance on promises in Non-Prosecution Agreement led to his guilty plea to state charges and his",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 9:08-cv-80736-KAM Document 209 Entered on FLSD Docket 07/09/2019 Page 4 of 20",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Water Management Dist., 647 F.3d 1296, 1302 (11th Cir. 2011) (“If at any point in the litigation the plaintiff ceases to meet all three requirements for constitutional standing, the case no longer presents a live case or controversy, and the federal court must dismiss the case for lack of subject matter jurisdiction.”); Phoenix of Broward, Inc. v. McDonald’s Corp., 489 F.3d 1156, 1161 (11th Cir. 2007) (“[T]he issue of constitutional standing is jurisdictional . . .”); National Parks Conservation Ass’n v. Norton, 324 F.3d 1229, 1242 (11th Cir. 2003) (“[B]ecause the constitutional standing doctrine stems directly from Article III’s ‘case or controversy’ requirement, this issue implicates our subject matter jurisdiction, and accordingly must be addressed as a threshold matter regardless of whether it is raised by the parties.”) (citation omitted).",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "In these proceedings, the only identified legal relief that Petitioners have sought pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney’s Office for the Southern District of Florida (“USAO-SDFL”). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners seek “is to invalidate the non-prosecution agreement”). But even assuming arguendo that Petitioners’ rights under the CVRA were violated when Epstein and the USAO-SDFL entered into the Non-Prosecution Agreement, constitutional due process guarantees do not allow either the Non-Prosecution Agreement – which by its terms induced Epstein to, inter alia, plead guilty to state criminal charges and serve an 18-month sentence of state incarceration3 – or the governmental",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "this Court need not reach or address those issues because an analysis of the third prong of the standing test incontrovertibly establishes the Petitioners’ lack of standing. Nonetheless, the circumstances which demonstrate Petitioners’ lack of a concrete injury traceable to government conduct are explored infra in Section II of this memorandum, which addresses how Petitioners’ claims and these proceedings lack constitutional ripeness.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "3 See also July 11, 2008 Hr’g Tr. at 20-21 (Petitioners’ acknowledgement that Epstein’s reliance on promises in Non-Prosecution Agreement led to his guilty plea to state charges and his",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "3",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-0000308",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Jeffrey Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"U.S. Attorney's Office for the Southern District of Florida",
|
||||
"USAO-SDFL"
|
||||
],
|
||||
"locations": [
|
||||
"Southern District of Florida"
|
||||
],
|
||||
"dates": [
|
||||
"July 11, 2008",
|
||||
"07/09/2019"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"9:08-cv-80736-KAM",
|
||||
"DE 99",
|
||||
"DOJ-OGR-0000308"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing with a clear and legible text. There are no visible redactions or damage to the document."
|
||||
}
|
||||
50
results/IMAGES001/DOJ-OGR-00000309.json
Normal file
50
results/IMAGES001/DOJ-OGR-00000309.json
Normal file
@ -0,0 +1,50 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "5",
|
||||
"document_number": "9:08-cv-80736",
|
||||
"date": null,
|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "obligations undertaken therein to be set aside.4 See, e.g., Santobello v. New York, 404 U.S. 257, 262 (1971) (\"[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.\"); United States v. Harvey, 869 F.2d 1439, 1443 (11th Cir. 1989) (\"Due process requires the government to adhere to the terms of any plea bargain or immunity agreement it makes.\"). Indeed, even if this Court were somehow to set aside the Non-Prosecution Agreement on the authority of the CVRA, and even if after consultation with Petitioners the United States determined that it would be proper and desirable to institute a criminal prosecution in the Southern District of Florida against Epstein on the criminal charges contemplated in the Non-Prosecution Agreement, the United States would still be constitutionally required to adhere to the negotiated terms of the Non-Prosecution Agreement. See, e.g., Santobello, 404 U.S. at 262; Harvey, 869 F.2d at 1443. Due process considerations further bar this Court from setting aside a non-prosecution agreement that grants contractual rights to a contracting party (Epstein) who has not been made a party to the proceedings before the Court. See, e.g., School Dist. of City of Pontiac v. Secretary of U.S. Dept. of Educ., 584 F.3d 253, 303 (6th Cir. 2009) (\"It is hornbook law that all parties to a contract are necessary in an action challenging its validity . . .\"); Dawavendewa v. Salt River Project Agr. Imp. & Power Dist., 276 F.3d 1150, 1157 (9th Cir. 2002) (\"[A] party to a contract is necessary, and if not susceptible to joinder, indispensable to litigation seeking to decimate that subsequent 18-month state incarceration). 4 To the extent that the Petitioners' requested invalidation of the Non-Prosecution Agreement would implicitly reject and nullify the correctness of both the state court's acceptance of Epstein's guilty plea and the resulting judgment of conviction -which were induced in part by the Non-Prosecution Agreement - such judicial action might raise additional questions about this Court's jurisdiction under the Rooker/Feldman doctrine. See, e.g., Casale v. Tillman, 558 F.3d 1258, 1260-61 (11th Cir. 2009); Powell v. Powell, 80 F.3d 464, 466-68 (11th Cir. 1996).",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "obligations undertaken therein to be set aside.4 See, e.g., Santobello v. New York, 404 U.S. 257, 262 (1971) (\"[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.\"); United States v. Harvey, 869 F.2d 1439, 1443 (11th Cir. 1989) (\"Due process requires the government to adhere to the terms of any plea bargain or immunity agreement it makes.\"). Indeed, even if this Court were somehow to set aside the Non-Prosecution Agreement on the authority of the CVRA, and even if after consultation with Petitioners the United States determined that it would be proper and desirable to institute a criminal prosecution in the Southern District of Florida against Epstein on the criminal charges contemplated in the Non-Prosecution Agreement, the United States would still be constitutionally required to adhere to the negotiated terms of the Non-Prosecution Agreement. See, e.g., Santobello, 404 U.S. at 262; Harvey, 869 F.2d at 1443. Due process considerations further bar this Court from setting aside a non-prosecution agreement that grants contractual rights to a contracting party (Epstein) who has not been made a party to the proceedings before the Court. See, e.g., School Dist. of City of Pontiac v. Secretary of U.S. Dept. of Educ., 584 F.3d 253, 303 (6th Cir. 2009) (\"It is hornbook law that all parties to a contract are necessary in an action challenging its validity . . .\"); Dawavendewa v. Salt River Project Agr. Imp. & Power Dist., 276 F.3d 1150, 1157 (9th Cir. 2002) (\"[A] party to a contract is necessary, and if not susceptible to joinder, indispensable to litigation seeking to decimate that subsequent 18-month state incarceration). 4 To the extent that the Petitioners' requested invalidation of the Non-Prosecution Agreement would implicitly reject and nullify the correctness of both the state court's acceptance of Epstein's guilty plea and the resulting judgment of conviction -which were induced in part by the Non-Prosecution Agreement - such judicial action might raise additional questions about this Court's jurisdiction under the Rooker/Feldman doctrine. See, e.g., Casale v. Tillman, 558 F.3d 1258, 1260-61 (11th Cir. 2009); Powell v. Powell, 80 F.3d 464, 466-68 (11th Cir. 1996).",
|
||||
"position": "main body"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"U.S. Dept. of Educ.",
|
||||
"Salt River Project Agr. Imp. & Power Dist."
|
||||
],
|
||||
"locations": [
|
||||
"New York",
|
||||
"Florida",
|
||||
"Pontiac",
|
||||
"United States"
|
||||
],
|
||||
"dates": [
|
||||
"1971",
|
||||
"1989",
|
||||
"2009",
|
||||
"2002",
|
||||
"1996"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"9:08-cv-80736",
|
||||
"404 U.S. 257",
|
||||
"869 F.2d 1439",
|
||||
"584 F.3d 253",
|
||||
"276 F.3d 1150",
|
||||
"558 F.3d 1258",
|
||||
"80 F.3d 464"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Epstein, with discussions on the Non-Prosecution Agreement and its implications. The text is mostly printed, with no visible handwriting or stamps. The document quality is clear and legible."
|
||||
}
|
||||
79
results/IMAGES001/DOJ-OGR-00000310.json
Normal file
79
results/IMAGES001/DOJ-OGR-00000310.json
Normal file
@ -0,0 +1,79 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "6",
|
||||
"document_number": "9:08-cv-01339-KAM Document 209 Filed 07/06/19 Page 6 of 20",
|
||||
"date": "07/06/2019",
|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 9:08-cv-01339-KAM Document 209 Filed 07/06/19 Page 6 of 20 contract.\"); Lomayaktewa v. Hathaway, 520 F.2d 1324, 1325 (9th Cir. 1975) (\"No procedural principle is more deeply imbedded in the common law than that, in an action to set aside a lease or a contract, all parties who may be affected by the determination of the action are indispensable.\"); see also National Licorice Co. v. NLRB, 309 U.S. 350, 362 (1940) (\"It is elementary that it is not within the power of any tribunal to make a binding adjudication of the rights in personam of parties not brought before it by due process of law.\").5 Additionally, a \"favorable ruling\" from this Court will not provide Petitioners with anything for the alleged CVRA violations that is not already available to them. For the due process reasons already discussed above, the United States must legally abide by the terms of the Non-Prosecution Agreement even if this Court should somehow set the agreement aside for Petitioners to consult further with the government attorney handling the case. Moreover, as will be explained in greater detail below, see infra at 8-12, Petitioners already have the present ability to confer with an attorney for the government about a federal criminal case against Epstein - whether or not the Non-Prosecution Agreement is set aside - because the investigation and potential federal prosecution of Epstein for crimes committed against the Petitioners and others remains a legally viable possibility.6 The present proceedings under the CVRA must accordingly be dismissed for lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought 5 Significantly, it is Epstein's contractual rights under the non-prosecution agreement that Petitioners seek to void through these proceedings. 6 Petitioners' present, as well as past, ability to confer with an attorney for the government also demonstrates that Petitioners fail to satisfy the first two prongs of the standing test: Petitioners have simply not suffered a concrete injury that is fairly traceable to the challenged government conduct. 5 DOJ-OGR-00000310",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 9:08-cv-01339-KAM Document 209 Filed 07/06/19 Page 6 of 20",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "contract.\"); Lomayaktewa v. Hathaway, 520 F.2d 1324, 1325 (9th Cir. 1975) (\"No procedural principle is more deeply imbedded in the common law than that, in an action to set aside a lease or a contract, all parties who may be affected by the determination of the action are indispensable.\"); see also National Licorice Co. v. NLRB, 309 U.S. 350, 362 (1940) (\"It is elementary that it is not within the power of any tribunal to make a binding adjudication of the rights in personam of parties not brought before it by due process of law.\").5",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Additionally, a \"favorable ruling\" from this Court will not provide Petitioners with anything for the alleged CVRA violations that is not already available to them. For the due process reasons already discussed above, the United States must legally abide by the terms of the Non-Prosecution Agreement even if this Court should somehow set the agreement aside for Petitioners to consult further with the government attorney handling the case. Moreover, as will be explained in greater detail below, see infra at 8-12, Petitioners already have the present ability to confer with an attorney for the government about a federal criminal case against Epstein - whether or not the Non-Prosecution Agreement is set aside - because the investigation and potential federal prosecution of Epstein for crimes committed against the Petitioners and others remains a legally viable possibility.6",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "The present proceedings under the CVRA must accordingly be dismissed for lack of standing because Petitioners simply have no injury that is likely to be redressed by a favorable ruling in these proceedings. See, e.g., Scott v. Taylor, 470 F.3d 1014, 1018 (11th Cir. 2006) (holding that there was no standing where it was speculative that remedy that Plaintiff sought",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "5 Significantly, it is Epstein's contractual rights under the non-prosecution agreement that Petitioners seek to void through these proceedings.",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "6 Petitioners' present, as well as past, ability to confer with an attorney for the government also demonstrates that Petitioners fail to satisfy the first two prongs of the standing test: Petitioners have simply not suffered a concrete injury that is fairly traceable to the challenged government conduct.",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "5",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000310",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Lomayaktewa",
|
||||
"Hathaway",
|
||||
"Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"NLRB",
|
||||
"DOJ"
|
||||
],
|
||||
"locations": [],
|
||||
"dates": [
|
||||
"07/06/2019",
|
||||
"1975",
|
||||
"1940",
|
||||
"2006"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"9:08-cv-01339-KAM",
|
||||
"520 F.2d 1324",
|
||||
"309 U.S. 350",
|
||||
"470 F.3d 1014",
|
||||
"DOJ-OGR-00000310"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to a case involving Jeffrey Epstein and alleged CVRA violations. The text is mostly printed, with some footnotes and a header/footer. There are no visible stamps or handwritten text."
|
||||
}
|
||||
70
results/IMAGES001/DOJ-OGR-00000311.json
Normal file
70
results/IMAGES001/DOJ-OGR-00000311.json
Normal file
@ -0,0 +1,70 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "7",
|
||||
"document_number": "9:08-cv-01339-KAM",
|
||||
"date": "07/09/2019",
|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 9:08-cv-01339-KAM Document 209 Filed 07/09/19 Page 7 of 20 would redress claimed injury). II. The Claims Raised in the Petition Are Not Constitutionally ripe, and These Proceedings Must Thus Be Dismissed for Lack of Subject Matter Jurisdiction. This Court must also dismiss these proceedings for lack of subject matter jurisdiction because the Petitioners' claims are not constitutionally ripe. Ripeness, like standing, \"originate[s] from the Constitution's Article III requirement that the jurisdiction of the federal courts be limited to actual cases and controversies.\" Elend v. Basham, 471 F.3d 1199, 1204-05 (11th Cir. 2006). \"The ripeness doctrine keeps federal courts from deciding cases prematurely,\" Beaulieu v. City of Alabaster, 454 F.3d 1219, 1227 (11th Cir. 2006), and \"protects [them] from engaging in speculation or wasting their resources through the review of potential or abstract disputes,\" Digital Props., Inc. v. City of Plantation, 121 F.3d 586, 589 (11th Cir.1997).\" United States v. Rivera, 613 F.3d 1046, 1050 (11th Cir. 2010); see also Pittman v. Cole, 267 F.3d 1269, 1278 (11th Cir. 2001) (\"The ripeness doctrine prevent[s] the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements . . . .\") (quoting Coalition for the Abolition of Marijuana Prohibition v. City of Atlanta, 219 F.3d 1301, 1315 (11th Cir. 2000) (citations and quotations omitted))). Under the ripeness doctrine, a court must therefore determine \"whether there is sufficient injury to meet Article III's requirement of a case or controversy and, if so, whether the claim is sufficiently mature, and the issues sufficiently defined and concrete, to permit effective decisionmaking by the court.\" In re Jacks, 642 F.3d 1323, 1332 (11th Cir. 2011) (quoting Cheffer v. Reno, 55 F.3d 1517, 1524 (11th Cir. 1995)). When evaluating whether a claim is ripe, a court considers: \"(1) the fitness of the issues for judicial decision, and (2) the hardship to the parties of withholding court consideration.\" Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967))); 6 DOJ-OGR-00000311",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 9:08-cv-01339-KAM Document 209 Filed 07/09/19 Page 7 of 20",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "would redress claimed injury). II. The Claims Raised in the Petition Are Not Constitutionally ripe, and These Proceedings Must Thus Be Dismissed for Lack of Subject Matter Jurisdiction. This Court must also dismiss these proceedings for lack of subject matter jurisdiction because the Petitioners' claims are not constitutionally ripe. Ripeness, like standing, \"originate[s] from the Constitution's Article III requirement that the jurisdiction of the federal courts be limited to actual cases and controversies.\" Elend v. Basham, 471 F.3d 1199, 1204-05 (11th Cir. 2006). \"The ripeness doctrine keeps federal courts from deciding cases prematurely,\" Beaulieu v. City of Alabaster, 454 F.3d 1219, 1227 (11th Cir. 2006), and \"protects [them] from engaging in speculation or wasting their resources through the review of potential or abstract disputes,\" Digital Props., Inc. v. City of Plantation, 121 F.3d 586, 589 (11th Cir.1997).\" United States v. Rivera, 613 F.3d 1046, 1050 (11th Cir. 2010); see also Pittman v. Cole, 267 F.3d 1269, 1278 (11th Cir. 2001) (\"The ripeness doctrine prevent[s] the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements . . . .\") (quoting Coalition for the Abolition of Marijuana Prohibition v. City of Atlanta, 219 F.3d 1301, 1315 (11th Cir. 2000) (citations and quotations omitted))). Under the ripeness doctrine, a court must therefore determine \"whether there is sufficient injury to meet Article III's requirement of a case or controversy and, if so, whether the claim is sufficiently mature, and the issues sufficiently defined and concrete, to permit effective decisionmaking by the court.\" In re Jacks, 642 F.3d 1323, 1332 (11th Cir. 2011) (quoting Cheffer v. Reno, 55 F.3d 1517, 1524 (11th Cir. 1995)). When evaluating whether a claim is ripe, a court considers: \"(1) the fitness of the issues for judicial decision, and (2) the hardship to the parties of withholding court consideration.\" Id. (quoting Cheffer, 55 F.3d at 1524 (citing Abbott Labs. v. Gardner, 387 U.S. 136, 149 (1967)));",
|
||||
"position": "main content"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "6",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000311",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Elend",
|
||||
"Basham",
|
||||
"Beaulieu",
|
||||
"Pittman",
|
||||
"Cole",
|
||||
"Rivera",
|
||||
"Jacks",
|
||||
"Cheffer",
|
||||
"Reno"
|
||||
],
|
||||
"organizations": [
|
||||
"City of Alabaster",
|
||||
"Digital Props., Inc.",
|
||||
"City of Plantation",
|
||||
"United States",
|
||||
"Coalition for the Abolition of Marijuana Prohibition",
|
||||
"City of Atlanta",
|
||||
"Abbott Labs.",
|
||||
"Gardner"
|
||||
],
|
||||
"locations": [
|
||||
"Alabaster",
|
||||
"Plantation",
|
||||
"Atlanta"
|
||||
],
|
||||
"dates": [
|
||||
"07/09/2019",
|
||||
"1967"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"9:08-cv-01339-KAM",
|
||||
"DOJ-OGR-00000311"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing, specifically a page from a legal brief or memorandum. The text is dense and includes numerous citations to legal precedents. There are no visible redactions or damage to the document."
|
||||
}
|
||||
54
results/IMAGES001/DOJ-OGR-00000312.json
Normal file
54
results/IMAGES001/DOJ-OGR-00000312.json
Normal file
@ -0,0 +1,54 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "8",
|
||||
"document_number": "9:08-cv-80736-KAM",
|
||||
"date": "07/06/2019",
|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 9:08-cv-80736-KAM Document 209 Entered on FLSD Docket 07/06/2019 Page 8 of 20 see also, e.g., Association For Children for Enforcement of Support, Inc. v. Conger, 899 F.2d 1164, 1165 (11th Cir. 1990). Under the doctrine, \"[a] claim is not ripe when it is based on speculative possibilities,\" In re Jacks, 642 F.3d 1323, 1332 (11th Cir. 2011), such as if the claim \"rests upon contingent future events that may not occur as anticipated, or indeed may not occur at all,\" Atlanta Gas Light Co. v. FERC, 140 F.3d 1392, 1404 (11th Cir. 1998) (quoting Texas v. United States, 523 U.S. 296, 300 (1998)). Indeed, \"[t]he ripeness doctrine is designed to prevent federal courts from engaging in such speculation and prematurely and perhaps unnecessarily reaching constitutional issues.\" Pittman, 267 F.3d at 1280. In these proceedings, the Petitioners have sought to set aside the Non-Prosecution Agreement between Epstein and the USAO-SDFL so that Petitioners can \"confer with the attorney for the Government\" about the possible filing of federal criminal charges against Epstein and the potential disposition of any such charges. See, e.g., July 11, 2008 Hr'g Tr. at 6-7 (seeking an \"[o]rder that the [non-prosecution] agreement that was negotiated is invalid\" so that Petitioners can exercise the right to confer with the government); id. at 19-20, 24; 18 U.S.C. § 3771(a)(5); see also DE 1 at 2 ¶ 5 (claiming that Petitioner was \"denied her rights\" under the CVRA because she \"received no consultation with the attorney for the government regarding the possible disposition of the charges\"). Notwithstanding the Non-Prosecution Agreement, Petitioners are and have been free to confer with attorneys for the government about the investigation and potential prosecution of Epstein. At least one attorney for the government (Assistant United States Attorney Villafaña from the USAO-SDFL) had spoken to Petitioners about the offenses committed against them by Epstein prior to the signing of the Non-Prosecution Agreement, see, e.g., July 11, 2008 Hr'g Tr. at 22 (acknowledging that prosecutors spoke to Petitioners \"about what happened\" to them); DE 7 DOJ-OGR-00000312",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 9:08-cv-80736-KAM Document 209 Entered on FLSD Docket 07/06/2019 Page 8 of 20",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "see also, e.g., Association For Children for Enforcement of Support, Inc. v. Conger, 899 F.2d 1164, 1165 (11th Cir. 1990). Under the doctrine, \"[a] claim is not ripe when it is based on speculative possibilities,\" In re Jacks, 642 F.3d 1323, 1332 (11th Cir. 2011), such as if the claim \"rests upon contingent future events that may not occur as anticipated, or indeed may not occur at all,\" Atlanta Gas Light Co. v. FERC, 140 F.3d 1392, 1404 (11th Cir. 1998) (quoting Texas v. United States, 523 U.S. 296, 300 (1998)). Indeed, \"[t]he ripeness doctrine is designed to prevent federal courts from engaging in such speculation and prematurely and perhaps unnecessarily reaching constitutional issues.\" Pittman, 267 F.3d at 1280. In these proceedings, the Petitioners have sought to set aside the Non-Prosecution Agreement between Epstein and the USAO-SDFL so that Petitioners can \"confer with the attorney for the Government\" about the possible filing of federal criminal charges against Epstein and the potential disposition of any such charges. See, e.g., July 11, 2008 Hr'g Tr. at 6-7 (seeking an \"[o]rder that the [non-prosecution] agreement that was negotiated is invalid\" so that Petitioners can exercise the right to confer with the government); id. at 19-20, 24; 18 U.S.C. § 3771(a)(5); see also DE 1 at 2 ¶ 5 (claiming that Petitioner was \"denied her rights\" under the CVRA because she \"received no consultation with the attorney for the government regarding the possible disposition of the charges\"). Notwithstanding the Non-Prosecution Agreement, Petitioners are and have been free to confer with attorneys for the government about the investigation and potential prosecution of Epstein. At least one attorney for the government (Assistant United States Attorney Villafaña from the USAO-SDFL) had spoken to Petitioners about the offenses committed against them by Epstein prior to the signing of the Non-Prosecution Agreement, see, e.g., July 11, 2008 Hr'g Tr. at 22 (acknowledging that prosecutors spoke to Petitioners \"about what happened\" to them); DE",
|
||||
"position": "main body"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "7",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000312",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Epstein",
|
||||
"Villafaña"
|
||||
],
|
||||
"organizations": [
|
||||
"USAO-SDFL"
|
||||
],
|
||||
"locations": [
|
||||
"Florida"
|
||||
],
|
||||
"dates": [
|
||||
"July 11, 2008",
|
||||
"07/06/2019"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"9:08-cv-80736-KAM",
|
||||
"DOJ-OGR-00000312"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Association For Children for Enforcement of Support, Inc. v. Conger. The text discusses the ripeness doctrine and its application to the case. The document includes citations to various court cases and statutes."
|
||||
}
|
||||
63
results/IMAGES001/DOJ-OGR-00000313.json
Normal file
63
results/IMAGES001/DOJ-OGR-00000313.json
Normal file
@ -0,0 +1,63 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "9",
|
||||
"document_number": "9:08-cv-80736",
|
||||
"date": "07/06/2019",
|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "48 at 6 ¶ 8; see also DE 99 at 3, and government attorneys have on multiple occasions offered to confer with Petitioners, see, e.g., July 11, 2008 Hr'g Tr. at 13 (“I will always confer, sit down with Jane Doc 1 and 2, with the two agents and Ms. Villafana. We’ll be happy to sit down with them.”). Indeed, on December 10, 2010, the United States Attorney for the Southern District of Florida, accompanied by supervisory and line prosecutors from the USAO-SDFL, personally conferred with Petitioners’ counsel and with Petitioner Jane Doe #1 and entertained discussion about Petitioners’ desires to see Epstein criminally prosecuted on federal charges.7 The United States Attorney and prosecutors in the USAO-SDFL have also corresponded with Petitioners’ counsel on multiple occasions about Petitioners’ desires to have Epstein criminally prosecuted on federal charges.8 Additionally, a number of districts outside the Southern District of Florida (e.g., the Southern District of New York and the District of New Jersey) share jurisdiction and venue with the Southern District of Florida over potential federal criminal charges based on the alleged sexual acts committed by Epstein against the Petitioners. Epstein is thus subject to potential prosecution for such acts in those districts. Furthermore, because of the nature of the allegations against Epstein, the filing of such potential charges against Epstein still remains temporally viable; charges for such sexual activities involving minors are not barred by the applicable 7 The United States Attorney also offered to confer with Jane Doe #2, but Jane Doe #2 declined the invitation and did not attend the meeting that was scheduled with the United States Attorney. 8 Since that time, the USAO-SDFL has been recused by the Department of Justice from prospective responsibility for any criminal investigation or potential prosecution relating to Epstein’s alleged sexual activities with minor females. The Department of Justice has reassigned responsibility for the investigation and potential prosecution of such criminal matters in the Southern District of Florida to the United States Attorney’s Office for the Middle District of Florida for consideration of any prosecutorial action that may be authorized and appropriate.",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "48 at 6 ¶ 8; see also DE 99 at 3, and government attorneys have on multiple occasions offered to confer with Petitioners, see, e.g., July 11, 2008 Hr'g Tr. at 13 (“I will always confer, sit down with Jane Doc 1 and 2, with the two agents and Ms. Villafana. We’ll be happy to sit down with them.”). Indeed, on December 10, 2010, the United States Attorney for the Southern District of Florida, accompanied by supervisory and line prosecutors from the USAO-SDFL, personally conferred with Petitioners’ counsel and with Petitioner Jane Doe #1 and entertained discussion about Petitioners’ desires to see Epstein criminally prosecuted on federal charges.7 The United States Attorney and prosecutors in the USAO-SDFL have also corresponded with Petitioners’ counsel on multiple occasions about Petitioners’ desires to have Epstein criminally prosecuted on federal charges.8",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Additionally, a number of districts outside the Southern District of Florida (e.g., the Southern District of New York and the District of New Jersey) share jurisdiction and venue with the Southern District of Florida over potential federal criminal charges based on the alleged sexual acts committed by Epstein against the Petitioners. Epstein is thus subject to potential prosecution for such acts in those districts. Furthermore, because of the nature of the allegations against Epstein, the filing of such potential charges against Epstein still remains temporally viable; charges for such sexual activities involving minors are not barred by the applicable",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "7 The United States Attorney also offered to confer with Jane Doe #2, but Jane Doe #2 declined the invitation and did not attend the meeting that was scheduled with the United States Attorney.",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "8 Since that time, the USAO-SDFL has been recused by the Department of Justice from prospective responsibility for any criminal investigation or potential prosecution relating to Epstein’s alleged sexual activities with minor females. The Department of Justice has reassigned responsibility for the investigation and potential prosecution of such criminal matters in the Southern District of Florida to the United States Attorney’s Office for the Middle District of Florida for consideration of any prosecutorial action that may be authorized and appropriate.",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Jane Doe #1",
|
||||
"Jane Doe #2",
|
||||
"Ms. Villafana",
|
||||
"Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"USAO-SDFL",
|
||||
"Department of Justice",
|
||||
"United States Attorney's Office"
|
||||
],
|
||||
"locations": [
|
||||
"Southern District of Florida",
|
||||
"Southern District of New York",
|
||||
"District of New Jersey",
|
||||
"Middle District of Florida"
|
||||
],
|
||||
"dates": [
|
||||
"July 11, 2008",
|
||||
"December 10, 2010",
|
||||
"07/06/2019"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"9:08-cv-80736",
|
||||
"DE 99",
|
||||
"DOJ-OGR-00000313"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein, with redactions present."
|
||||
}
|
||||
69
results/IMAGES001/DOJ-OGR-00000314.json
Normal file
69
results/IMAGES001/DOJ-OGR-00000314.json
Normal file
@ -0,0 +1,69 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "10",
|
||||
"document_number": "9:08-cv-80736",
|
||||
"date": "07/13/2019",
|
||||
"document_type": "Court Document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 9:08-cv-80736 Document 496-1 Entered on FLSD Docket 07/13/2019 Page 10 of 20\nstatutes of limitations. See 18 U.S.C. §§ 3283, 3299. Petitioners are free to contact the United States Attorney's Office in those districts and seek to confer with government attorneys in those offices about investigating and potentially prosecuting Epstein based on the alleged federal crimes committed against them.9\nPetitioners nonetheless have appeared to contend throughout these proceedings that the many opportunities that they have been given to consult with the attorneys for the government about Epstein's offenses and the potential charges against Epstein - opportunities which continue to be available to Petitioners - are not meaningful under the CVRA due to the existence of the Non-Prosecution Agreement. According to Petitioners, the Non-Prosecution Agreement has given Epstein a \"free pass\" on federal criminal charges for the offenses he committed against Petitioners and others. See, e.g., DE 9 at 15 (characterizing Non-Prosecution Agreement as \"a 'free pass' from the federal government\"), 2 (contending that the Non-Prosecution Agreement \"allowed [Epstein] . . . to escape all federal prosecution for dozens of serious federal sex offenses against minors\"), 7 (\"the wealthy defendant has escaped all federal punishment\"), 12 (\"[T]he agreement prevents federal prosecution of the defendant for numerous sex offenses.\"); DE 77 at 2 (describing Non-Prosecution Agreement as \"an agreement that blocked federal prosecution of Epstein for the multitude of sex offenses he committed again [sic] the victims\"), 17 (\"The [Non-\n9 The USAO-SDFL has no present knowledge about whether the United States Attorney's Offices in those districts have opened any investigations into the allegations that have been made against Epstein, whether those offices are even aware of those allegations or the evidence supporting them, or what investigative or prosecutorial actions, if any, those offices might take in the future. Nonetheless, should any investigation be initiated involving such allegations, the evidence gathered in the Southern District of Florida could be disclosed to federal prosecutors and federal grand juries in New York or New Jersey. See\n9\nDOJ-OGR-0000314",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 9:08-cv-80736 Document 496-1 Entered on FLSD Docket 07/13/2019 Page 10 of 20",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "statutes of limitations. See 18 U.S.C. §§ 3283, 3299. Petitioners are free to contact the United States Attorney's Office in those districts and seek to confer with government attorneys in those offices about investigating and potentially prosecuting Epstein based on the alleged federal crimes committed against them.9",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Petitioners nonetheless have appeared to contend throughout these proceedings that the many opportunities that they have been given to consult with the attorneys for the government about Epstein's offenses and the potential charges against Epstein - opportunities which continue to be available to Petitioners - are not meaningful under the CVRA due to the existence of the Non-Prosecution Agreement. According to Petitioners, the Non-Prosecution Agreement has given Epstein a \"free pass\" on federal criminal charges for the offenses he committed against Petitioners and others. See, e.g., DE 9 at 15 (characterizing Non-Prosecution Agreement as \"a 'free pass' from the federal government\"), 2 (contending that the Non-Prosecution Agreement \"allowed [Epstein] . . . to escape all federal prosecution for dozens of serious federal sex offenses against minors\"), 7 (\"the wealthy defendant has escaped all federal punishment\"), 12 (\"[T]he agreement prevents federal prosecution of the defendant for numerous sex offenses.\"); DE 77 at 2 (describing Non-Prosecution Agreement as \"an agreement that blocked federal prosecution of Epstein for the multitude of sex offenses he committed again [sic] the victims\"), 17 (\"The [Non-",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "9 The USAO-SDFL has no present knowledge about whether the United States Attorney's Offices in those districts have opened any investigations into the allegations that have been made against Epstein, whether those offices are even aware of those allegations or the evidence supporting them, or what investigative or prosecutorial actions, if any, those offices might take in the future. Nonetheless, should any investigation be initiated involving such allegations, the evidence gathered in the Southern District of Florida could be disclosed to federal prosecutors and federal grand juries in New York or New Jersey. See",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "9",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-0000314",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"United States Attorney's Office",
|
||||
"USAO-SDFL"
|
||||
],
|
||||
"locations": [
|
||||
"Florida",
|
||||
"New York",
|
||||
"New Jersey",
|
||||
"Southern District of Florida"
|
||||
],
|
||||
"dates": [
|
||||
"07/13/2019"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"9:08-cv-80736",
|
||||
"18 U.S.C. §§ 3283, 3299",
|
||||
"DE 9",
|
||||
"DE 77",
|
||||
"DOJ-OGR-0000314"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Epstein, discussing the Non-Prosecution Agreement and its implications. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
|
||||
}
|
||||
95
results/IMAGES001/DOJ-OGR-00000315.json
Normal file
95
results/IMAGES001/DOJ-OGR-00000315.json
Normal file
@ -0,0 +1,95 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "11",
|
||||
"document_number": "9:08-cv-80736",
|
||||
"date": "07/16/2019",
|
||||
"document_type": "Court Document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "Case 9:08-cv-80736 Document 596-4 Entered on FLSD Docket 07/16/2019 Page 11 of 20\n\nProsecution Agreement] barred prosecution of the federal sexual offenses that Epstein had committed against Jane Doe #1 and Jane Doe #2 . . .\").10 That is simply not so.\n\nContrary to Petitioners' contentions, there has been no disposition by the government of any federal criminal charges against Epstein. No federal charges involving Petitioners have ever been brought against Epstein, and no such federal charges have been resolved. The Non-Prosecution Agreement about which Petitioners complain disposes of no federal criminal charges against Epstein, and that agreement does not bar the United States from bringing federal criminal charges against Epstein. Instead, when addressing potential federal criminal charges against Epstein, the USAO-SDFL merely agreed in the Non-Prosecution Agreement that:\n\non the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below.\n\nand that\n\nAfter timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed.\n\nNon-Prosecution Agreement at 2 (emphasis added).\n\nThus, the Non-Prosecution Agreement simply obligated the government not to prosecute Epstein in the Southern District of Florida for the offenses set forth in the Non-Prosecution\n\n10 This Court has also previously described the Non-Prosecution Agreement as \"an agreement under which . . . the U.S. Attorney's Office would agree not to prosecute Epstein for federal offenses.\" DE 99 at 2-3. That description of the Non-Prosecution Agreement, however, was not based on the Court's interpretation of the terms of the Non-Prosecution Agreement, but was instead based on \"allegations\" by Petitioners that the Court concluded were \"not yet supported by evidence\" but upon which the Court nonetheless relied \"solely to provide the context for the threshold issues addressed in\" its September 26, 2011 Order. Id. at 2 n.2.\n\n10\n\nDOJ-OGR-00000315",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Case 9:08-cv-80736 Document 596-4 Entered on FLSD Docket 07/16/2019 Page 11 of 20",
|
||||
"position": "header"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Prosecution Agreement] barred prosecution of the federal sexual offenses that Epstein had committed against Jane Doe #1 and Jane Doe #2 . . .\").10 That is simply not so.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Contrary to Petitioners' contentions, there has been no disposition by the government of any federal criminal charges against Epstein. No federal charges involving Petitioners have ever been brought against Epstein, and no such federal charges have been resolved. The Non-Prosecution Agreement about which Petitioners complain disposes of no federal criminal charges against Epstein, and that agreement does not bar the United States from bringing federal criminal charges against Epstein. Instead, when addressing potential federal criminal charges against Epstein, the USAO-SDFL merely agreed in the Non-Prosecution Agreement that:",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "and that",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed.",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Non-Prosecution Agreement at 2 (emphasis added).",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Thus, the Non-Prosecution Agreement simply obligated the government not to prosecute Epstein in the Southern District of Florida for the offenses set forth in the Non-Prosecution",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "10 This Court has also previously described the Non-Prosecution Agreement as \"an agreement under which . . . the U.S. Attorney's Office would agree not to prosecute Epstein for federal offenses.\" DE 99 at 2-3. That description of the Non-Prosecution Agreement, however, was not based on the Court's interpretation of the terms of the Non-Prosecution Agreement, but was instead based on \"allegations\" by Petitioners that the Court concluded were \"not yet supported by evidence\" but upon which the Court nonetheless relied \"solely to provide the context for the threshold issues addressed in\" its September 26, 2011 Order. Id. at 2 n.2.",
|
||||
"position": "bottom"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "10",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000315",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Epstein",
|
||||
"Jane Doe #1",
|
||||
"Jane Doe #2",
|
||||
"R. Alexander Acosta"
|
||||
],
|
||||
"organizations": [
|
||||
"USAO-SDFL",
|
||||
"Federal Bureau of Investigation",
|
||||
"U.S. Attorney's Office"
|
||||
],
|
||||
"locations": [
|
||||
"Southern District of Florida",
|
||||
"Florida"
|
||||
],
|
||||
"dates": [
|
||||
"07/16/2019",
|
||||
"September 26, 2011"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"9:08-cv-80736",
|
||||
"DE 99",
|
||||
"DOJ-OGR-00000315"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
|
||||
}
|
||||
71
results/IMAGES001/DOJ-OGR-00000317.json
Normal file
71
results/IMAGES001/DOJ-OGR-00000317.json
Normal file
@ -0,0 +1,71 @@
|
||||
{
|
||||
"document_metadata": {
|
||||
"page_number": "13",
|
||||
"document_number": "9:08-cv-80736-KAM Document 596-1 Entered on FLSD Docket 07/05/2019",
|
||||
"date": "07/05/2019",
|
||||
"document_type": "court document",
|
||||
"has_handwriting": false,
|
||||
"has_stamps": false
|
||||
},
|
||||
"full_text": "been curtailed by the Non-Prosecution Agreement - to discuss the possibility of pursuing federal criminal charges against Epstein.13 Nothing precludes Petitioners from doing so, and there is nothing to indicate that Petitioners' wishes to confer with government attorneys in those districts would be rebuffed in any way. Indeed, it would be rank speculation by Petitioners to contend otherwise.\n\nHere, Petitioners have acknowledged that the best relief they can hope to obtain through these proceedings is the ability to confer with the attorneys for the government. See, e.g., July 11, 2008 Hr'g Tr. at 7 (agreeing that \"the best [Petitioners] can get\" is the \"right to confer\").\n\nYet, under the circumstances, a claim that Petitioners have been denied the opportunity to confer with the attorney for the government about the filing and disposition of criminal charges against Epstein is premature and constitutionally unripe. \"This is plainly the type of hypothetical case that [a court] should avoid deciding.\" Association for Children for Enforcement of Support, Inc. v. Conger, 899 F.2d 1164, 1166 (11th Cir. 1990). Any speculation by Petitioners that they might prospectively be denied the opportunity to confer with the government about still-legally-viable federal charges against Epstein simply cannot ripen Petitioners' claims. See id. (recognizing that courts \"do not generally decide cases based on a party's predicted conduct\").\n\nFor these reasons, Petitioners' claims in these proceedings should be dismissed for lack of subject matter jurisdiction. See, e.g., In re Jacks, 642 F.3d 1323, 1332 (11th Cir. 2011) (holding that claims that are \"based on events that may take place in the future\" are to be \"dismissed for lack of jurisdiction\") (citing Greenbriar, Ltd. v. City of Alabaster, 881 F.2d 1570, 1574 n.7 (11th Cir. 1989) (\"[R]ipeness goes to whether the district court had subject matter jurisdiction\").\n\n13 Petitioners could also approach the United States Attorney's Office for the Middle District of Florida but, due to that office's recusal-based derivative prosecutorial responsibilities in the Southern District of Florida, see supra note 8, the Non-Prosecution Agreement would constrain the possible filing of federal charges by that office in the Southern District of Florida.\n\n12\nDOJ-OGR-00000317",
|
||||
"text_blocks": [
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "been curtailed by the Non-Prosecution Agreement - to discuss the possibility of pursuing federal criminal charges against Epstein.13 Nothing precludes Petitioners from doing so, and there is nothing to indicate that Petitioners' wishes to confer with government attorneys in those districts would be rebuffed in any way. Indeed, it would be rank speculation by Petitioners to contend otherwise.",
|
||||
"position": "top"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Here, Petitioners have acknowledged that the best relief they can hope to obtain through these proceedings is the ability to confer with the attorneys for the government. See, e.g., July 11, 2008 Hr'g Tr. at 7 (agreeing that \"the best [Petitioners] can get\" is the \"right to confer\").",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "Yet, under the circumstances, a claim that Petitioners have been denied the opportunity to confer with the attorney for the government about the filing and disposition of criminal charges against Epstein is premature and constitutionally unripe. \"This is plainly the type of hypothetical case that [a court] should avoid deciding.\" Association for Children for Enforcement of Support, Inc. v. Conger, 899 F.2d 1164, 1166 (11th Cir. 1990). Any speculation by Petitioners that they might prospectively be denied the opportunity to confer with the government about still-legally-viable federal charges against Epstein simply cannot ripen Petitioners' claims. See id. (recognizing that courts \"do not generally decide cases based on a party's predicted conduct\").",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "For these reasons, Petitioners' claims in these proceedings should be dismissed for lack of subject matter jurisdiction. See, e.g., In re Jacks, 642 F.3d 1323, 1332 (11th Cir. 2011) (holding that claims that are \"based on events that may take place in the future\" are to be \"dismissed for lack of jurisdiction\") (citing Greenbriar, Ltd. v. City of Alabaster, 881 F.2d 1570, 1574 n.7 (11th Cir. 1989) (\"[R]ipeness goes to whether the district court had subject matter jurisdiction\").",
|
||||
"position": "middle"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "13 Petitioners could also approach the United States Attorney's Office for the Middle District of Florida but, due to that office's recusal-based derivative prosecutorial responsibilities in the Southern District of Florida, see supra note 8, the Non-Prosecution Agreement would constrain the possible filing of federal charges by that office in the Southern District of Florida.",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "12",
|
||||
"position": "footer"
|
||||
},
|
||||
{
|
||||
"type": "printed",
|
||||
"content": "DOJ-OGR-00000317",
|
||||
"position": "footer"
|
||||
}
|
||||
],
|
||||
"entities": {
|
||||
"people": [
|
||||
"Epstein"
|
||||
],
|
||||
"organizations": [
|
||||
"Association for Children for Enforcement of Support, Inc.",
|
||||
"United States Attorney's Office"
|
||||
],
|
||||
"locations": [
|
||||
"Florida",
|
||||
"Southern District of Florida",
|
||||
"Middle District of Florida"
|
||||
],
|
||||
"dates": [
|
||||
"July 11, 2008",
|
||||
"07/05/2019"
|
||||
],
|
||||
"reference_numbers": [
|
||||
"9:08-cv-80736-KAM",
|
||||
"DOJ-OGR-00000317"
|
||||
]
|
||||
},
|
||||
"additional_notes": "The document appears to be a court filing related to the Epstein case, discussing the Non-Prosecution Agreement and its implications. The text is mostly printed, with no visible handwriting or stamps. The document is likely a PDF or scanned image of a court document."
|
||||
}
|
||||
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Reference in New Issue
Block a user