{
  "document_metadata": {
    "page_number": "2 of 2",
    "document_number": "549",
    "date": "12/17/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 549 Filed 12/17/21 Page 2 of 2\n\n(11/01/21 Tr. at 16 (citing United States v. Saldarriaga, 204 F.3d 50 (2d Cir. 2000))), that the government \"had an improper motive\" (id. (citing United States v. Regan, 103 F.3d 1072 (2d Cir. 1997))), \"affirmative evidence by the defense that goes to the thoroughness of the investigation\" (id. at 17), \"[t]he length of the investigation, the investigative techniques used, and the fact that the defendant was not initially a target of the investigation\" (id. at 19 (quoting United States v. Duncan, No. 18 Cr. 289, 2019 WL 2210663 (S.D.N.Y. 2019))), and questions about \"who [the case agents] talked to, what documents they subpoenaed, and when,\" (id. at 20), among other lines of questioning.\n\nWithout knowing details of the defense's anticipated direct examination of the law enforcement witnesses, however, the Government does not seek relief at this time.\n\nRespectfully submitted,\n\nDAMIAN WILLIAMS\nUnited States Attorney\n\nBy: s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York\n\nCc: Defense Counsel (by ECF)",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 549 Filed 12/17/21 Page 2 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "(11/01/21 Tr. at 16 (citing United States v. Saldarriaga, 204 F.3d 50 (2d Cir. 2000))), that the government \"had an improper motive\" (id. (citing United States v. Regan, 103 F.3d 1072 (2d Cir. 1997))), \"affirmative evidence by the defense that goes to the thoroughness of the investigation\" (id. at 17), \"[t]he length of the investigation, the investigative techniques used, and the fact that the defendant was not initially a target of the investigation\" (id. at 19 (quoting United States v. Duncan, No. 18 Cr. 289, 2019 WL 2210663 (S.D.N.Y. 2019))), and questions about \"who [the case agents] talked to, what documents they subpoenaed, and when,\" (id. at 20), among other lines of questioning.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Without knowing details of the defense's anticipated direct examination of the law enforcement witnesses, however, the Government does not seek relief at this time.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,\nDAMIAN WILLIAMS\nUnited States Attorney\n\nBy: s/\nMaurene Comey\nAlison Moe\nLara Pomerantz\nAndrew Rohrbach\nAssistant United States Attorneys\nSouthern District of New York",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Cc: Defense Counsel (by ECF)",
      "position": "bottom"
    }
  ],
  "entities": {
    "people": [
      "Damian Williams",
      "Maurene Comey",
      "Alison Moe",
      "Lara Pomerantz",
      "Andrew Rohrbach"
    ],
    "organizations": [
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "11/01/21",
      "12/17/21",
      "2000",
      "1997",
      "2019"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "549",
      "18 Cr. 289"
    ]
  },
  "additional_notes": "The document appears to be a court filing in a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and easy to read."
}