{
  "document_metadata": {
    "page_number": "59",
    "document_number": "452",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 59 of 84\n\nOn September 3, 2021, the Court ordered the Government to \"disclose to the Defendant the identities of all unnamed co-conspirators alleged in the S2 indictment to whom it will refer at trial.\" (Order at 1, Dkt. No. 335). The Court further ordered the Government to \"disclose all co-conspirator statements it intends to offer at trial no later than October 11, as consistent with this Court's scheduling order.\" (Id. at 2).\n\nAccordingly, on October 11, 2021, the Government produced its exhibit list and Jencks Act material to the defendant. The Jencks Act materials and exhibits contained the only co-conspirator statements in the Government's possession that will be offered at trial. It also disclosed the identities of the individuals to whom it may refer at trial as co-conspirators and informed the defendant that it \"has produced all co-conspirator statements which it intends to offer at trial . . . in the Government's production [that day] or in its previous productions.\" (Def. Mot. 1 Ex. 1 at 1). The Government further noted that \"[t]o the extent the Government learns of additional co-conspirator statements as it continues to prepare for trial, it will produce those statements in connection with its ongoing obligation to produce Jencks Act material.\" (Id.).\n\nB. Discussion\n\nThe Government has complied with its pre-trial disclosure obligations, consistent with the Court's orders and on a schedule with deadlines well in advance of trial. As of October 11, the Government produced all co-conspirator statements in its possession that it intends to offer at trial. To the extent that the Government learns of additional co-conspirator statements as it prepares for trial—such as in a session preparing a witness for trial—it will produce those statements as part of its ongoing Jencks Act obligations.\n\n58\n\nDOJ-OGR-00006767",
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      "content": "Case 1:20-cr-00330-PAE Document 452 Filed 11/12/21 Page 59 of 84",
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    {
      "type": "printed",
      "content": "On September 3, 2021, the Court ordered the Government to \"disclose to the Defendant the identities of all unnamed co-conspirators alleged in the S2 indictment to whom it will refer at trial.\" (Order at 1, Dkt. No. 335). The Court further ordered the Government to \"disclose all co-conspirator statements it intends to offer at trial no later than October 11, as consistent with this Court's scheduling order.\" (Id. at 2).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Accordingly, on October 11, 2021, the Government produced its exhibit list and Jencks Act material to the defendant. The Jencks Act materials and exhibits contained the only co-conspirator statements in the Government's possession that will be offered at trial. It also disclosed the identities of the individuals to whom it may refer at trial as co-conspirators and informed the defendant that it \"has produced all co-conspirator statements which it intends to offer at trial . . . in the Government's production [that day] or in its previous productions.\" (Def. Mot. 1 Ex. 1 at 1). The Government further noted that \"[t]o the extent the Government learns of additional co-conspirator statements as it continues to prepare for trial, it will produce those statements in connection with its ongoing obligation to produce Jencks Act material.\" (Id.).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "B. Discussion",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government has complied with its pre-trial disclosure obligations, consistent with the Court's orders and on a schedule with deadlines well in advance of trial. As of October 11, the Government produced all co-conspirator statements in its possession that it intends to offer at trial. To the extent that the Government learns of additional co-conspirator statements as it prepares for trial—such as in a session preparing a witness for trial—it will produce those statements as part of its ongoing Jencks Act obligations.",
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      "type": "printed",
      "content": "58",
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      "content": "DOJ-OGR-00006767",
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  "entities": {
    "people": [],
    "organizations": [
      "Government",
      "Court"
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    "locations": [],
    "dates": [
      "September 3, 2021",
      "October 11, 2021",
      "11/12/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "452",
      "335",
      "DOJ-OGR-00006767"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is well-formatted and easy to read. There are no visible redactions or damage to the document."
}