{
  "document_metadata": {
    "page_number": "87",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 87 of 239 motions, the suppression motions overlap in fact and argument, and accordingly, the Government responds to both motions in this section. As set forth herein, the defendant's suppression motions challenging a judicially approved grand jury subpoena should be denied without a hearing for multiple reasons. As an initial matter, the defendant's claim that the Government “circumvented” Martindell fails because the Government issued a valid grand jury subpoena, sought judicial authorization to permit compliance with the subpoena, and obtained materials from Boies Schiller that otherwise would have been covered by the relevant protective order only after receiving such authorization. In any event, even if the Government's motion did not satisfy Martindell, Martindell provides no basis to suppress evidence, and the defendant cites no authority in support of that request. Second, the defendant's claim that the subpoena was a warrantless search in violation of the Fourth Amendment fails because she has not established standing to challenge a judicially approved grand jury subpoena issued to a third party, and because the subpoena was entirely lawful. Even if she had standing, her claim still fails because suppression would be improper under the good faith exception and the inevitable discovery doctrine. Third, the defendant's claim that the subpoena violated her Fifth Amendment rights fails because, among other things, such a violation requires coercion and state action. Fourth, the defendant's claim that the Government violated the Due Process Clause is meritless, as the Government's conduct was not, by any reasonable definition, outrageous or conscience shocking. And finally, the defendant's request for a hearing should be denied because she has proffered no admissible evidence to support her accusations of Government misconduct; instead, she relies entirely on an anonymously sourced article that, as detailed herein, she cites to describe certain events that simply did not occur. Accordingly, the defendant's suppression motions should be denied. 60 DOJ-OGR-00003021",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 87 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "motions, the suppression motions overlap in fact and argument, and accordingly, the Government responds to both motions in this section. As set forth herein, the defendant's suppression motions challenging a judicially approved grand jury subpoena should be denied without a hearing for multiple reasons. As an initial matter, the defendant's claim that the Government “circumvented” Martindell fails because the Government issued a valid grand jury subpoena, sought judicial authorization to permit compliance with the subpoena, and obtained materials from Boies Schiller that otherwise would have been covered by the relevant protective order only after receiving such authorization. In any event, even if the Government's motion did not satisfy Martindell, Martindell provides no basis to suppress evidence, and the defendant cites no authority in support of that request. Second, the defendant's claim that the subpoena was a warrantless search in violation of the Fourth Amendment fails because she has not established standing to challenge a judicially approved grand jury subpoena issued to a third party, and because the subpoena was entirely lawful. Even if she had standing, her claim still fails because suppression would be improper under the good faith exception and the inevitable discovery doctrine. Third, the defendant's claim that the subpoena violated her Fifth Amendment rights fails because, among other things, such a violation requires coercion and state action. Fourth, the defendant's claim that the Government violated the Due Process Clause is meritless, as the Government's conduct was not, by any reasonable definition, outrageous or conscience shocking. And finally, the defendant's request for a hearing should be denied because she has proffered no admissible evidence to support her accusations of Government misconduct; instead, she relies entirely on an anonymously sourced article that, as detailed herein, she cites to describe certain events that simply did not occur. Accordingly, the defendant's suppression motions should be denied.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "60",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003021",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Boies Schiller",
      "Government"
    ],
    "locations": [],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00003021"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, discussing the defendant's suppression motions and the government's response. The text is well-formatted and printed, with no visible handwriting or stamps."
}