{
  "document_metadata": {
    "page_number": "8",
    "document_number": "706",
    "date": "07/12/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 706 Filed 07/12/22 Page 8 of 12\n\nleading questions about what Jane told the Government, the defendant has attempted to establish a basis for impeachment by contradiction. As the Second Circuit explained in Ramirez and as Wright & Miller agree, it undermines the Federal Rules of Evidence to use cross to open a door to put extrinsic evidence before the jury that is otherwise prohibited by those Rules. See Ramirez, 609 F.3d at 500 n.1; Wright & Miller, Fed. Prac. & Procedure § 6119. The Court should not permit it.\n\nIII. The Court Should Preclude Testimony by Alexander Hamilton As Captured By His Affidavit\n\nThe defendant intends to call Alexander Hamilton and, in Rule 26.2 discovery, produced an affidavit from him that is attached as Exhibit A. This appears to be the signed declaration the defense referenced on cross of Kate, in which the None of the topics in the affidavit are admissible evidence, and the Court should preclude testimony from Hamilton along those lines.\n\nSecond, the affidavit says that Kate was a \"coke head.\" (Ex. A ¶ 14). Kate already testified that she was addicted to cocaine during the relevant time period. Tr. 1205. This evidence is therefore not impeaching as to the relevant time period.\n\n8\nDOJ-OGR-00011260",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 706 Filed 07/12/22 Page 8 of 12",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "leading questions about what Jane told the Government, the defendant has attempted to establish a basis for impeachment by contradiction. As the Second Circuit explained in Ramirez and as Wright & Miller agree, it undermines the Federal Rules of Evidence to use cross to open a door to put extrinsic evidence before the jury that is otherwise prohibited by those Rules. See Ramirez, 609 F.3d at 500 n.1; Wright & Miller, Fed. Prac. & Procedure § 6119. The Court should not permit it.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "III. The Court Should Preclude Testimony by Alexander Hamilton As Captured By His Affidavit",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant intends to call Alexander Hamilton and, in Rule 26.2 discovery, produced an affidavit from him that is attached as Exhibit A. This appears to be the signed declaration the defense referenced on cross of Kate, in which the None of the topics in the affidavit are admissible evidence, and the Court should preclude testimony from Hamilton along those lines.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Second, the affidavit says that Kate was a \"coke head.\" (Ex. A ¶ 14). Kate already testified that she was addicted to cocaine during the relevant time period. Tr. 1205. This evidence is therefore not impeaching as to the relevant time period.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "8",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00011260",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jane",
      "Alexander Hamilton",
      "Kate"
    ],
    "organizations": [
      "Second Circuit",
      "Wright & Miller"
    ],
    "locations": [],
    "dates": [
      "07/12/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "706",
      "609 F.3d at 500 n.1",
      "§ 6119",
      "Ex. A ¶ 14",
      "Tr. 1205",
      "DOJ-OGR-00011260"
    ]
  },
  "additional_notes": "The document appears to be a court filing with redactions. The redactions are likely due to sensitive information being removed."
}