{
  "document_metadata": {
    "page_number": "163",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "choices reflected in the criminal discovery rules.\" Id. Second, doing so \"risks invading 'the inviolable function of the jury' in our criminal justice system.\" Id. at 281 (citation omitted). Accordingly, if the \"defense raises a factual dispute that is inextricably intertwined with a defendant's potential culpability, a judge cannot resolve that dispute on a Rule 12(b) motion.\" Id. The exception to this rule is \"extraordinarily narrow\" because, in the normal course, the \"government must make a detailed presentation of the entirety of the evidence before a district court can dismiss an indictment on sufficiency grounds,\" which the Government is not required to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for insufficiency of the evidence. First, however, the court explained that the question was ripe because \"(1) Defendant has stipulated to the entire record that is relevant to Count I; (2) the Government has had several opportunities to make a proffer of any additional facts, to conduct any subsequent investigation, and to ask the Court for further delay to seek more evidence; and (3) because the record is limited to the chat.\" Id. at 9. Accordingly, \"[t]he transcripts themselves provide the Court with all of the relevant undisputed facts to decide the motion.\" Id. Here, of course, that is simply not the case and, in particular, there is no stipulation as to the entire relevant record. Under the relevant legal standard, the defendant's statements were material if they could have led to the discovery of other evidence or could influence the factfinder in the defendant's civil case. Evaluating that standard necessarily implicates facts beyond the deposition testimony itself and Judge Preska's unsealing order,50 such as identification of the allegedly defamatory of Count Six, stating that the \"testimony is . . . far afield from the sex trafficking and sexual abuse 136 DOJ-OGR-00003097",
  "text_blocks": [
    {
      "type": "printed",
      "content": "choices reflected in the criminal discovery rules.\" Id. Second, doing so \"risks invading 'the inviolable function of the jury' in our criminal justice system.\" Id. at 281 (citation omitted). Accordingly, if the \"defense raises a factual dispute that is inextricably intertwined with a defendant's potential culpability, a judge cannot resolve that dispute on a Rule 12(b) motion.\" Id. The exception to this rule is \"extraordinarily narrow\" because, in the normal course, the \"government must make a detailed presentation of the entirety of the evidence before a district court can dismiss an indictment on sufficiency grounds,\" which the Government is not required to do at the motion-to-dismiss stage. Id. at 282 (internal quotation marks and citation omitted). That point is underscored by United States v. Nitsche, 843 F. Supp. 2d 4 (D.D.C. 2011), on which the defendant relies. There, the district court dismissed an indictment in a child enticement case for insufficiency of the evidence. First, however, the court explained that the question was ripe because \"(1) Defendant has stipulated to the entire record that is relevant to Count I; (2) the Government has had several opportunities to make a proffer of any additional facts, to conduct any subsequent investigation, and to ask the Court for further delay to seek more evidence; and (3) because the record is limited to the chat.\" Id. at 9. Accordingly, \"[t]he transcripts themselves provide the Court with all of the relevant undisputed facts to decide the motion.\" Id. Here, of course, that is simply not the case and, in particular, there is no stipulation as to the entire relevant record. Under the relevant legal standard, the defendant's statements were material if they could have led to the discovery of other evidence or could influence the factfinder in the defendant's civil case. Evaluating that standard necessarily implicates facts beyond the deposition testimony itself and Judge Preska's unsealing order,50 such as identification of the allegedly defamatory of Count Six, stating that the \"testimony is . . . far afield from the sex trafficking and sexual abuse",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "50 The defendant observes that Judge Preska redacted some of the statements that form the basis",
      "position": "footnote"
    },
    {
      "type": "printed",
      "content": "136",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003097",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Judge Preska"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [
      "D.D.C."
    ],
    "dates": [
      "04/16/21",
      "2011"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "Case 1:20-cr-00330-PAE",
      "843 F. Supp. 2d 4",
      "Count I",
      "Count Six",
      "DOJ-OGR-00003097"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, with a formal and technical tone. The text includes citations to legal precedents and references to specific court documents. There are no visible redactions or damage to the document."
}