{
  "document_metadata": {
    "page_number": "166",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 166 of 239\n\nF.2d at 929). Offenses may be joined \"where the same evidence may be used to prove each count or if the counts have a sufficient logical connection.\" United States v. Page, 657 F.3d 126, 129 (2d Cir. 2011) (internal quotation marks and citations omitted). \"For purposes of analysis under Rule 8(a),\" however, \"no one characteristic is always sufficient to establish 'similarity' of offenses, and each case depends largely on its own facts.\" United States v. Blakney, 941 F.2d 114, 116 (2d Cir. 1991) (internal quotations and citations omitted). For instance, in United States v. Werner, 620 F.2d 922 (2d Cir. 1980), the \"Second Circuit found sufficient similarity between two cargo thefts that occurred two years apart and only one of which was violent in nature,\" because \"'both offenses arose out of [defendant's] scheme to use his position as an insider . . . to obtain money or property carried by it.'\" United States v. Smith, No. 05 Cr. 922 (DLC), 2007 WL 980431, at *2 (S.D.N.Y. Apr. 3, 2007), aff'd, 348 F. App'x 636, 638 (2d Cir. 2009) (first alteration in original) (quoting Werner, 620 F2d at 927).\n\nJoinder is also proper for \"distinct criminal acts where they originated from a common scheme.\" United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, \"[t]he law in this circuit clearly supports the joinder of underlying substantive crimes with perjury counts where, as here, the false declarations concern the substantive offenses.\" United States v. Potamitis, 739 F.2d 784, 791 (2d Cir. 1984); see United States v. Sweig, 441 F.2d 114, 118 (2d Cir. 1971).\n\nFalse statements can \"concern\" or be connected with substantive offenses even if they were not made as part of an investigation into the specific substantive conduct. See United States v. Ruiz, 894 F.2d 501, 505 (2d Cir. 1990) (joining false statements on loan applications with perjury about \"attempts to secure Senate Ethics Committee approval\" of \"consulting fees'); United States v. Broccolo, 797 F. Supp. 1185, 1190-91 (S.D.N.Y. 1992) (joining fraud counts with a false statement count).\n\n139\nDOJ-OGR-00003100",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 166 of 239",
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      "type": "printed",
      "content": "F.2d at 929). Offenses may be joined \"where the same evidence may be used to prove each count or if the counts have a sufficient logical connection.\" United States v. Page, 657 F.3d 126, 129 (2d Cir. 2011) (internal quotation marks and citations omitted). \"For purposes of analysis under Rule 8(a),\" however, \"no one characteristic is always sufficient to establish 'similarity' of offenses, and each case depends largely on its own facts.\" United States v. Blakney, 941 F.2d 114, 116 (2d Cir. 1991) (internal quotations and citations omitted). For instance, in United States v. Werner, 620 F.2d 922 (2d Cir. 1980), the \"Second Circuit found sufficient similarity between two cargo thefts that occurred two years apart and only one of which was violent in nature,\" because \"'both offenses arose out of [defendant's] scheme to use his position as an insider . . . to obtain money or property carried by it.'\" United States v. Smith, No. 05 Cr. 922 (DLC), 2007 WL 980431, at *2 (S.D.N.Y. Apr. 3, 2007), aff'd, 348 F. App'x 636, 638 (2d Cir. 2009) (first alteration in original) (quoting Werner, 620 F2d at 927).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Joinder is also proper for \"distinct criminal acts where they originated from a common scheme.\" United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 5113139, at *2 (E.D.N.Y. Oct. 19, 2018) (citing Werner, 620 F.2d at 927). Specifically in the context of perjury, \"[t]he law in this circuit clearly supports the joinder of underlying substantive crimes with perjury counts where, as here, the false declarations concern the substantive offenses.\" United States v. Potamitis, 739 F.2d 784, 791 (2d Cir. 1984); see United States v. Sweig, 441 F.2d 114, 118 (2d Cir. 1971).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "False statements can \"concern\" or be connected with substantive offenses even if they were not made as part of an investigation into the specific substantive conduct. See United States v. Ruiz, 894 F.2d 501, 505 (2d Cir. 1990) (joining false statements on loan applications with perjury about \"attempts to secure Senate Ethics Committee approval\" of \"consulting fees'); United States v. Broccolo, 797 F. Supp. 1185, 1190-91 (S.D.N.Y. 1992) (joining fraud counts with a false statement count).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "139",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003100",
      "position": "footer"
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  ],
  "entities": {
    "people": [],
    "organizations": [
      "United States",
      "Second Circuit",
      "Senate Ethics Committee",
      "DOJ"
    ],
    "locations": [
      "New York",
      "Eastern District of New York"
    ],
    "dates": [
      "04/16/21",
      "2011",
      "1991",
      "1980",
      "Apr. 3, 2007",
      "2009",
      "Oct. 19, 2018",
      "1984",
      "1971",
      "1990",
      "1992"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "05 Cr. 922",
      "15 Cr. 601",
      "DOJ-OGR-00003100"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}