{
  "document_metadata": {
    "page_number": "134",
    "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 134 of 239\n\nb. Discussion\n\nThe defendant argues that the Due Process Clause requires the suppression of the evidence the Government obtained pursuant to subpoena, including the April and July 2016 depositions, and the dismissal of Counts Five and Six. The defendant falls far short of carrying the very heavy burden of establishing a due process violation to warrant the extraordinary relief she seeks. The Government's conduct did not, by any reasonable definition, \"shock the conscience.\"\n\nThe defendant has not identified explicitly the component of her due process rights that the Government allegedly violated. As she does not seem to allege that the Government deprived her of life, liberty, or property in an unfair manner (nor could she), it seems that the defendant is claiming that the Government's supposed misrepresentation of facts to the Court violated her substantive due process rights. As set forth above, the Government did not mislead Chief Judge McMahon in connection with its ex parte application. The Government did not violate the law, much less participate in any violation that so \"shocks the conscience\" as to require suppression as a matter of substantive due process.\n\nThe defendant has neither specified what \"fundamental right\" the Government allegedly violated nor provided legal authority supporting her claim. She cites United States v. Valentine, 820 F.2d 565, 570 (2d Cir. 1987), seemingly to argue that her right to a fair trial has been implicated because of the same alleged prosecutorial misconduct in connection with the modification of the protective order described above. However, the defendant cites no authority for the proposition that such misconduct (assuming, of course, it occurred, which it did not) would warrant the relief she now seeks, and the primary case she relies upon is readily distinguishable. In Valentine, the defendant was convicted of perjury based upon grand jury testimony in which he denied that he was given a loan to make a political contribution. 820 F.2d at 570. The Second Circuit reversed\n\n107\n\nDOJ-OGR-00003068",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 134 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "b. Discussion",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The defendant argues that the Due Process Clause requires the suppression of the evidence the Government obtained pursuant to subpoena, including the April and July 2016 depositions, and the dismissal of Counts Five and Six. The defendant falls far short of carrying the very heavy burden of establishing a due process violation to warrant the extraordinary relief she seeks. The Government's conduct did not, by any reasonable definition, \"shock the conscience.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant has not identified explicitly the component of her due process rights that the Government allegedly violated. As she does not seem to allege that the Government deprived her of life, liberty, or property in an unfair manner (nor could she), it seems that the defendant is claiming that the Government's supposed misrepresentation of facts to the Court violated her substantive due process rights. As set forth above, the Government did not mislead Chief Judge McMahon in connection with its ex parte application. The Government did not violate the law, much less participate in any violation that so \"shocks the conscience\" as to require suppression as a matter of substantive due process.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant has neither specified what \"fundamental right\" the Government allegedly violated nor provided legal authority supporting her claim. She cites United States v. Valentine, 820 F.2d 565, 570 (2d Cir. 1987), seemingly to argue that her right to a fair trial has been implicated because of the same alleged prosecutorial misconduct in connection with the modification of the protective order described above. However, the defendant cites no authority for the proposition that such misconduct (assuming, of course, it occurred, which it did not) would warrant the relief she now seeks, and the primary case she relies upon is readily distinguishable. In Valentine, the defendant was convicted of perjury based upon grand jury testimony in which he denied that he was given a loan to make a political contribution. 820 F.2d at 570. The Second Circuit reversed",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "107",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003068",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Chief Judge McMahon"
    ],
    "organizations": [
      "Government",
      "Court",
      "Second Circuit"
    ],
    "locations": [],
    "dates": [
      "April 2016",
      "July 2016",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "820 F.2d 565",
      "DOJ-OGR-00003068"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is from a legal proceeding and includes citations to legal cases and statutes."
}