{
  "document_metadata": {
    "page_number": "6",
    "document_number": "239",
    "date": "04/23/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 239 Filed 04/23/21 Page 6 of 6\nPage 6\nbased on the Government's review to date and the OPR report, the Government has no reason to believe that a document supporting the above-described defenses under the NPA in this case exists.\nIndeed, as the Court noted in its April 16, 2021 Opinion, OPR thoroughly investigated the circumstances of the negotiation of the NPA and issued extensive findings from its investigation.\nNothing in the OPR report supports the defendant's assertion that the NPA bars this prosecution.\n(April 16, 2021 Opinion, Dkt. No. 207 at 5-6 (\"Maxwell has already received access to an unusually large amount of information about the NPA's negotiation history in the form of the OPR report and yet identifies no evidence that the Department of Justice made any promises not contained in the NPA.\"); at 8 (\"No record evidence suggests that prosecutors promised anything beyond what was spelled out in writing.\"))\nThe Government does not intend to seek any additional materials from other offices or agencies relating to the NPA, and the Court has already denied the defense's request for discovery relating to the NPA.\nRespectfully submitted,\nAUDREY STRAUSS\nUnited States Attorney\nBy: /s Alison Moe / Maurene Comey\nLara Pomerantz / Andrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\nCc: All Counsel of Record (By ECF)",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 239 Filed 04/23/21 Page 6 of 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "based on the Government's review to date and the OPR report, the Government has no reason to believe that a document supporting the above-described defenses under the NPA in this case exists.\nIndeed, as the Court noted in its April 16, 2021 Opinion, OPR thoroughly investigated the circumstances of the negotiation of the NPA and issued extensive findings from its investigation.\nNothing in the OPR report supports the defendant's assertion that the NPA bars this prosecution.\n(April 16, 2021 Opinion, Dkt. No. 207 at 5-6 (\"Maxwell has already received access to an unusually large amount of information about the NPA's negotiation history in the form of the OPR report and yet identifies no evidence that the Department of Justice made any promises not contained in the NPA.\"); at 8 (\"No record evidence suggests that prosecutors promised anything beyond what was spelled out in writing.\"))\nThe Government does not intend to seek any additional materials from other offices or agencies relating to the NPA, and the Court has already denied the defense's request for discovery relating to the NPA.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "AUDREY STRAUSS\nUnited States Attorney",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "By: /s Alison Moe / Maurene Comey\nLara Pomerantz / Andrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Cc: All Counsel of Record (By ECF)",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "AUDREY STRAUSS",
      "Alison Moe",
      "Maurene Comey",
      "Lara Pomerantz",
      "Andrew Rohrbach",
      "Maxwell"
    ],
    "organizations": [
      "Department of Justice"
    ],
    "locations": [
      "Southern District of New York"
    ],
    "dates": [
      "04/23/21",
      "April 16, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 239",
      "Dkt. No. 207"
    ]
  },
  "additional_notes": "The document appears to be a court filing in a criminal case, with a formal tone and language typical of legal documents. The text is clear and legible, with no apparent redactions or damage."
}